It seems that Dr. Scheier raised some fair interest and discussion re
"administrative fees" in lieu of an IDC rate. Let me add my quick cent and a
half.

For the Feds at least, a primary concern is the concept of consistency in
proposing, accumulating, and billing for costs (Shades of Cost Accounting
Standards!).  So to try an administrative fee where one has not been placed in
use and therefore in the IDC rate proposal process is a significant concern.

From what I have been able to discern from the many comments so far is that
folks are wanting to recover some costs in a manner other than the IDC rate
which some federal agencies are either capping or eliminating.

Therefore, I would expect that it would be easier to use an IDC rate and defend
it on the basis of that rate being based upon REAL costs rather than an
administrative fee that is intended to recover some "phantom" costs that are
not recovered/recoverable as real costs.

I might also comment that while A-88 is intended to preclude differing rates
for different agencies, we all know that this has gone by the wayside. BUT,
nonetheless, I would attempt to use the argument that the cognizant agency
(DHHS, DoD, etc.) has  negotiated IDC rates that are INTENDED to apply to all
federal agencies absent specific authority, regulation, etc., to the contrary.

I hope this might add some insight but if someone has a specific question that
they would like to address to me, I would try to help. Use the email address
above, xxxxxx@onrhq.onr.navy.mil, or 614-292-4344