Hello-
Here is how we are handling the 30% Total Federal Funds (TFF) limit in indirect cost (IDC), to include subs'. When we are lead applicant, we are opting to take the hit because (1) the reason we might exceed 30% TFF, when combined, is caused by the lead applicant getting IDC on the first $25,000 of the subaward budget and (2) for simplicity sake. We think trying to spread this to all participants will be a nightmare, since 30% TFF is a moving target.  (Also, some other universities said they will not accept less than 30%). Here is our method when we are lead:

• Encourage PIs to set a total for each sub, for instance $100,000 to include direct and indirect costs. That way, we will know the maximum IDC to expect from each.

• Set a deadline for sub budgets a week before normal, to allow us to deal with ensuring all IDC, added together, are less than 30% of TFF.

• Require our subs to limit their IDC to the lower of (1) 30% of their request and (2) their negotiated rate. (If we have subs using 10% and others that could exceed 30% of their total request, we may discuss with NIFA.)

• Add all IDC together (ours and all subs). If using our negotiated rate leads to exceeding 30% TFF, we will reduce our portion (as lead), reducing either IDC or a non-IDC-bearing cost.

When we are not lead on the proposal, we will request (and have requested) the lead institution do the same.

Jane Balch Burns, CPA, CRA, CIA, MPA
Interim Director & Compliance Officer
UTIA Office of Sponsored Programs
225 Morgan Hall, 2621 Morgan Circle Drive Knoxville, TN 37996

(865) 974-7123
xxxxxx@utk.edu 

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