Key question: Is the company  U.S.-based, or foreign? If foreign, there may be a limit on IDC recovery or no recovery at all will be allowed. (I didn't see any restriction in the R21 parent announcement, but I do remember encountering such a limitation on IDC recovery for foreign institutions with other NIH grant types. It would be a good idea to check with the grant management specialist identified in the FOA before submission.

Michael Spires, M.A., M.S.
Senior Proposal Analyst
Office of Contracts and Grants
xxxxxx@colorado.edu

3100 Marine Street, Room 475 | 572 UCB | Boulder, CO 80309-0572
Ph: 303.492.6646 | Fx: 303.492.6421

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lawrence Waxler
Sent: Monday, July 28, 2014 9:44 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Question on F&A for company without NICRA (R21)

Caroline,

Under the new OMNI Circular, the Federal government is allowing a 10% rate for any agency with no negotiated rate.

If the company wants anything difference/higher, given that the new regs are not final from each agencies perspective and won't be until December, you should probably contact the NIH program officer to get a read on what they will allow or what process they might suggest.

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

>>> Caroline Leopold <xxxxxx@LEOPOLDGRANTS.COM> 7/28/2014 10:10 AM >>>
I am providing pre-award consulting with a digital health company who has partnered with a university PI to submit an R21 for NIH's October deadline.

The company's role is substantial and wants to be a consortium partner.
Multiple staff at the company will serve as key personnel and are allocated effort in the budget. However, the company does not have a negotiated indirect cost rate agreement (NICRA).

I am more familiar with the F&A rules of SBIR/STTR in regards to companies.

I have reviewed the NIH FAQ at:

http://oalm.od.nih.gov/IndirectCostsFAQ#processstart

It appears as if the company can add a reasonable indirect rate into the NIH grant application and then negotiate with the NIH if there is a strong possibility of an award.

I fear that I am overly optimistic and misreading the guidelines. That is why I am turning the experts here at RESADM-L.

Any guidance on or offlist would be greatly appreciated. Thank you so much.

Best Regards,
Caroline

--
Caroline Leopold, GPC
Grants Consultant and Medical Writer
Leopold Grants Consulting
xxxxxx@leopoldgrants.com
LinkedIn Profile <http://www.linkedin.com/in/cleopold/>

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 Instructions on how to use the RESADM-L Mailing List, including
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 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help
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