If you charge lower IDC rates to for-profit (industrial) sponsors, how do
you justify that with the A-21 statement that "...each institution's
indirect cost rate process must be appropriately designed to ensure that
federal sponsors do not in any way subsidize the indirect costs of other
sponsors, specifically activities sponsored by industry and foreign
governments" [G.1.a.(3)]?  Granted, most of us charge lower rates for
clinical trials, but we justify it by saying that they are "testing" not
research - at least that's what we say to DHHS.  What we would say to
the IRS would probably be a little different.
 I must admit that we are currently struggling with the same issues
with regard to industry-sponsored basic research.  How do you, on the one hand,
meet your responsibility to the feds, but on the other hand stay competitive
with for-profit sponsors?  Frankly, I suspect that even if everyone charged
for-profits their full federal IDC rate, the research could still be done
more cheaply in university labs than in company labs, they just do not want
to admit it.

Doug Wilkerson, Ph.D.           VOICE:  (419) 381-4252
Assoc. V.P. for Research        FAX:    (419) 381-4262
Professor of Pharmacology       e-mail: xxxxxx@GEMINI.MCO.EDU
Medical College of Ohio
3000 Arlington Ave.
Toledo, OH 43614