For years we have had an agreement through our State Department of HHS
funded by the Federal Centers for Medicare & Medicaid Services (CMS).
Because the University is considered to be a State agency under CMS
guidelines, the State was able to use our waived F&A as “State
share” to draw Federal funds.

In an effort to streamline their business, our long-standing agreement
was combined with other programs so that now our relationship with the
State is through another agency, i.e. we are now a subcontractor in a
larger agreement awarded to another agency.

Our State contacts are saying that, since we are now a subcontractor
rather than working directly with the State, they are no longer able to
count our waived F&A and therefore the amount of Federal funds that they
can draw will decline by that amount.

I cannot find anything in any of the Federal Circulars (A-87 or A-21)
that would support that position.

Anyone encounter this situation and have some suggestions, advice,
etc.?

Larry

~~~~~~~~~~~~~~~~~~~~~~~
Larry Waxler, Director
Office of Sponsored Programs
University of Southern Maine
1 Chamberlain Avenue
P.O. Box 9300
Portland, ME  04104-9300
Telephone: 207-780-4413
Telefax: 207-780-4927

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