In response to Jean Humphries' questions regarding the MTDC
modifiers.

RE:  tuition.  At Rochester, this has always been one of our
exclusions, but I think if you read the A-21 revision, it says
that the changes are effective for the establishment of
indirect cost rates for all fiscal years beginning on or
after January 1.  I might be wrong on this, but I think your
rate agreement may hold.

Something I do know more about is subrecipients vs. vendors.
We use the concept of substantive work for subrecipients as
follows:  "Project activities which are a primary purpose of
a research program which, for whatever reason, are not
conducted at the University.  These activities constitute a
significant portion of the research program and require the
leadership and direction of a responsbile investigator located
at the worksite of a cooperating institution."

If you read the subrecipient vs vendor definition in OMB
Circular A-133, that will also give you guidance.

With respect to subawards and the $25k exclusion, you can take
that one time for the project duration.  Generally, our vendor
relationships are done through purchase orders and are equipment
related, therefore they fall under our equipment exclusion.
However, there are times when you may issue a purchase order for
something other than equipment (e.g., supply of gases, maintenance
contracts, etc.).  In those cases, we have been known to make an
exception to charging indirect costs after looking at the impact on
the project.

Hope this is helpful.

Jane Youngers
Director, Research and Project Administration
University of Rochester
xxxxxx@mvs.cc.rochester.edu