A preference is not a policy.  In the University of California's application of its IDC exception process, we would not approve an exception with this type of sponsor statement.  We would need a clear, unambiguous statement.  If they really don't want to pay IDC, their policy should say that.

I particularly dislike these types of "encouragement" statements.  It tends to get our PIs in the middle because they start thinking that their potential funding is in jeopardy.

I've gotten pushback from non-executive federal agencies (ones that don't have a reporting line to OMB) that they don't have to acknowledge our standard costing principles since technically the circulars don't apply to them.  I tend to push back on them - I let them know that there is still a cost to doing business, and our F&A rate agreements are the best measure we have in accounting for those costs.

Michael Joseph Kusiak
xxxxxx@ucop.edu
510-987-0659

Research Policy Analysis and Coordination
University of California, Office of the President

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of BURCHARD, LORI
Sent: Tuesday, March 25, 2014 9:29 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Indirect Costs from NHPRC

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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