Tom (et al):

Just because they are on the short form doesn't mean they have to use Salaries &
Wages as their base.  According to A-21, H.1.a., "[t]he institution may use
either the salaries and wages (see subsection 2) or modified total direct costs
(see subsection 3) as distribution basis."  MTDC is previously defined in part
as including the first $25,000 of each subcontract.  So they could charge F&A
depending upon their basis.

Just for fun, if they were on the S&W basis, and you were their subcontractor,
would you be able to charge F&A at your rate?  Or suppose you were the prime and
they were the sub on S&W basis, could they use your rate and base?

Yes to the first and no to the second.  You are allowed by agreement with the
fed to charge your F&A to all sponsored projects at the rate and basis agreed
(unless restricted by agreement or law).  Now if the prime restricted your F&A
recovery and you agreed to it, then you're restricted.  All A21 says is that
each institutions' F&A rates are negotiated by HHS/DCAA and that the rates must
be used.  Public Law 87-638 may mitigate this, but I don't have access to the
document.

"Roberts, Tom" wrote:

> There was recent discussion on this list related to prime contractors
> charging overhead on the first $25,000 of subcontracts.  Can anybody tell me
> if there is a reference that allows a prime contractor to charge overhead on
> the first $25,000 of a subcontract if this is not specifically referenced in
> the prime contractors indirect cost rate agreement?  This prime contractor
> is on the short form.  Any help would be greatly appreciated.  Thanks in
> advance.
>
> Tom
> _______________________________________________________
>
> Thomas J. Roberts, M.P.A.
> Director, Office of Contracts and Grants
> Florida Gulf Coast University
> 10501 FGCU Blvd. South
> Fort Myers, FL  33965-6565
> Telephone (941) 590-7021
> Fax (941) 590-7034
> e-mail <xxxxxx@fgcu.edu>
>
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--
Greg Schmidt
Manager, Contract & Grant Accounting
Florida A&M University
201 FHAC
Tallahassee, FL  32307-3200

DUNS:  623751831

College of the Year - 1997

voice:   850 561-2956
fax:     850 561-2461

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