Ted,
I agree with your practice.  In same situations, we both the subs and our own
institution to collect their 8% shares.  Likewise, when we have been a sub on
DEd flow-thru, we have collected our 8%.  You might try to explain it to your PI
by telling him that the government recognizes that all grantees--regardless of
"tier"--have administrative costs.  (That's why we all have to have our own
negotiated rate.)  The sub's 8% covers its personnel administration, accounting,
etc. and your institution's 8% covers all the paperwork to administer the
subgrant.  Somewhat simplistic, but it may do the trick.  Good luck.
Barbara

"Knous, Ted" wrote:

> I was hoping someone on the list could help with this issue:
> We have a major grant from the Department of Education with a limitation on
> the indirects, as usual, to 8% of TMDC. This grant has a number of subgrants
> and we have been collecting our 8% on the TMDC and allowing the subgrants to
> collect their 8% TMDC of their subgrant. The primary PI says that the grant
> has a restriction of 8% and that we are actually collecting 16% on the
> subgrants, thus violating Education's rule. I have taken the approach that
> since A-21 allows full indirects on the first $25k by the primary grantor
> and full indirects by the subgrantor, and education limits the indirects to
> 8% TMDC, that we are adhering to their rule by collecting on the full amount
> and allowing our subgrantors to collect on their portion. I need help on
> this one????
>
> Ted
> ----------------------------------------------------------------------------
> Ted R. Knous, Ph.D.
> Associate Dean for Research
>         And Graduate Studies
> The Graduate College/RPS
> University of Wisconsin-Stout
> 11 Harvey Hall
> Menomonie, WI 54751
>
> Voice: 715-232-1126
> Fax:  715-232-1749
> xxxxxx@uwstout.edu <mailto:xxxxxx@uwstout.edu>
> ----------------------------------------------------------------------------
> -
>
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Barbara H. Gray, Director
Research & Grants Administration
College of Charleston
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