[Flex] subaward IDC question - NSF convergence accelerator proposal

[Theresa Gordon]

Hi all,
The following is from Mark Hanson regarding this question:

If there is acceptable support for the 46% and we receive it and can evaluate it -- a CPA-developed rate proposal or the proposal has been submitted to the USG -- we may be able to review and negotiate that or a lower rate. If not, and there are otherwise acceptable grounds for a subaward vs. a vendor relationship, the prospective subawardee could simply agree to accept the 10% de minimis rate. If the prospective subawardee is unwilling to submit such records to support the 46% rate we'd have no basis on which to assess it, no basis to agree on any rate over 10%, and likely would have concerns whether we can fulfill our pre-award subrecipient evaluation and monitoring functions under the UG.

Hope this helps!
Theresa

From: flex-bounces at whoi.edu <flex-bounces at whoi.edu> On Behalf Of Karen Schwamb
Sent: Monday, June 7, 2021 3:43 PM
To: FLEX <flex at whoi.edu>
Subject: [Flex] subaward IDC question - NSF convergence accelerator proposal


Hi all,

I have not run into this before - we have a small business subaward on this proposal.  They do not have a negotiated rate agreement and their IDC rate is 46%.

The quote below is from the PAPPG - can they propose with the 46% rate? It sounds like with award this may be negotiated then, but I'm just not sure.
NSF grantees will use the domestic subrecipient’s applicable U.S. Federally negotiated indirect cost rate(s). If no such rate exists, the NSF grantee may either negotiate a rate or will fund the subrecipient using the de minimis indirect cost rate recovery of 10% of modified total direct costs.
Thanks for your help,

Karen



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Karen Schwamb / Administrative Associate

Applied Ocean Physics and Engineering Department

Woods Hole Oceanographic Institution

266 Woods Hole Rd., MS 12

Woods Hole, MA  02543

Telephone:  508-289-2675


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