Lori,

We just went through this with a pending proposal at NHPRC.  We prepped our project director with a list of bullet points, including our non-waiver policy and what the new supercircular intends.  NHPRC program officer would not budge.  Our PD asked outright if we would be considered non-competitive if we didn't waive IDC and we got a round-about answer that indicated to us that if we insisted on charging it, we would not be funded.  We approved an indirect cost waiver because the applying unit has so few grants and so few grant opportunities.  We did send a revised budget to NHPRC, reducing the direct cost salary match and substituting the unrecoverable IDC.  However, we felt we needed to be clear that we weren't actually reducing effort; we were just not including it anymore as formal committed cost share.

This agency is so small that I don't believe going higher would have made a difference, and may have just sealed a rejection deal for us.  I found this particular case very troubling because the change in the rules came in the midst of the review process.  I was left to wonder if all other applicants were being asked to waive their IDC, or if we were being treated differently for some reason.  At least now I know that they are probably applying the same new rules to everyone in this round of proposals.

Barbara

Barbara H. Gray
Director of Sponsored Programs
East Carolina University
Greenville Centre, Room 2906
2200 South Charles Boulevard
Greenville, NC  27858-4363
Telephone:  252-328-9977
Fax:  252-328-4363
Email:  xxxxxx@ecu.edu
Web:  www.ecu.edu/osp

Hi All:

Does anyone have experience receiving an award including indirect costs from the National Historical Publications and Records Commission for a research project?  The NHPRC proposal guidelines state that “The NHPRC will recognize other indirect cost rates already negotiated between its applicants and other Federal agencies”.  After submitting a proposal we received a message offering an opportunity to respond to reviewer comments that included the following:

"In addition, the Commission Staff wanted to draw your attention to the following areas:
1.  The Commission prefers that the applicant cover indirect costs through cost sharing [see 36CFR1206.50(b)(3)]. If you wish to submit a revised budget along with your response, you may do so."

It is our institutional policy to request full indirect costs on grant proposals unless specifically prohibited to do so by the proposal guidelines.  We do not want to voluntarily forego indirect costs, but we don't want to jeopardize the chance of the proposal if it is more than just a preference.  Has anyone else responded to this type of notice?

Thanks, Lori

Lori A. Burchard
Director, Sponsored Programs
Kent State University
330-672-7946

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