Research Administration Office

University of California

Memo Operating Guidance

89-28

November 13, 1989

Subject: U.S. Department of Education Strengthening Research Library Resources Program -- Indirect Cost Rate

The U.S. Department of Education recently issued guidelines for the Strengthening Research Library Resources Program which stated that "effective October 1, 1989 for all FY '90 funds, it will be the policy of the Department of Education ... not to allow on campus research indirect cost rates" for this program. These guidelines instruct the grantee "to submit an appropriate indirect cost rate to their cognizant Federal agency (HHS, DOD, or other) that specifically includes" this program in its cost allocation plan. (See Attachment 1.)

The Research Administration Office wrote to HHS Region IX, recommending that the General Administration (GA) and Sponsored Projects Administration (SPA) components of the currently negotiated research indirect cost rates for the University of California campuses be used for these grants. (See Attachment 2.) However, we were recently informed by HHS headquarters staff that HHS and the Department of Education have agreed to allow only the GA component of-an approved indirect cost research rate to be charged to these grants.

For those campuses which have already submitted proposals under this program, you may have to adjust the rate requested if you receive an award. The Research Administration Office will issue a class waiver for this program based on non-applicability of certain components.

Refer: Kip Meader

ATSS 8-582-3817

(415) 642-3817

Subject Index: 08

Organization: F-255

Samuela Evans

ATSS 8-582-3045

(415) 642-3045

David F. Mears

Director

Research Administration Office

Attachment


UNITED STATES DEPARTMENT OF EDUCATION

WASHINGTON. D.C. 20202

Beginning with all FY-90 new and continuation grants under this program, Grants and Contracts Service, (GCS) staff will no longer accept the research indirect cost rate if requested by an applicant. We are not taking this position with any of the FY-89 grants since notification of this change in policy was not provided to applicants in advance of submission of applications and GCS has already awarded FY-S9 continuation grants using the research indirect cost rates.

Effective October 1, 1989 for all FY'90 funds, it will be the policy of the Department of Education, Grants and Contracts Service to not allow "on campus research indirect cost rates" for the Strengthening Research Library Resources Program - Title II-C of the HEA.

This decision was developed by representatives from Grants and Contracts Service, and Library Program, Office of Educational Research and Improvement (OERI). The Department of Health and Human Services, the cognizant agency for establishment of indirect cost rate for most IHE's was also consulted. The determining factor in the final decision to disallow "research" rates was that the primary purpose of these grants is to preserve and improve access to unique library research resources (i.e., this activity does not involve "research").

Grantees are requested to submit an appropriate indirect cost rate to their cognizant Federal agency (HHS, DOD, or other) that specifically includes the Strengthening Research Library Resources Program in its cost allocation plan.


November 3, 1989

Mr. David Low, Director

Division of Cost Allocation

Department of Health and Human Services

50 United Nations Plaza

San Francisco, CA 94102

Dear Mr. Low:

The U.S. Department of Education recently issued guidelines for the Strengthening Research Library Resources Program which stated that "effective October 1, 1989 for all FY '90 funds, it will be the policy of the Department of Education ...not to allow on campus research indirect cost rates" for this program. These guidelines instruct the grantee "to submit an appropriate indirect cost rate to their cognizant Federal agency (HHS, DOD, or other) that specifically includes" this program in its cost allocation plan. (See Attachment 1).

Mr. Talesnik has said he was not interested in negotiating special rates for this program. He recommended that applicable components of the current rate be used instead. I propose that the currently negotiated GA and SPA components of the campus research rates be used for this program. For your review, I have enclosed other material which should provide you adequate background for this proposal.

If you concur, reissuing the A-88 agreements would not be required. The University would refer Department of Education personnel to your office for confirmation of the proposed rate if necessary.

Research Administration

cc: Director Mears