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  1. Hi thanks for your questions. The prime is a FFP IDIQ and each year an Order for Commercial Supplies is given to us to obligate the current year's funding. So that is why I referred to it as a FFP Award (also for simplicity as I know a lot of people don't work with FFP IDIQs, I didn't think there would be a difference compliance wise) So we are the prime and we are contracting out to different universities (hence subcontractors) My question on the 2 CFR was a response to the suggestion that our subcontractors are compliant to the 2 CFR - so I wondered why we, as a Non-Federal Institutions, wouldn't also be subject to the clause (s) [referring to the end clause..]. A lot here, hopefully this clarifies...
  2. Totally with your Patrick - that was my initial suggestion, but it got push back from the PIs because they wanted to provide a strict budget to make sure the funds were allocated correctly to get the work got done (I suggested provided a sample budget instead but let the projects figure it out). From a project point of view, they are concerned that the subs won't allocate enough labor to actually do the work (which is why we've arrived to this conversation since its a trade off between direct and indirect costs...)
  3. Educate me... why would we (as a Non-Federal Entity) not be subject to the 2 CFR but our subcontractors (Universities) would? Our main reason for mandating the 10% indirects is so that the departments have enough funds to run the project. Otherwise, if they use 50% for indirects (as their Nicra may show), they won't have enough funding for their direct costs. The question is whether mandating a 10% indirect rate is compliant, considering this is a Federal FFP IDIQ. My initial thought is that since this is a federal award, the institutions have the right to charge their Nicra and we can't mandate lessor. However, since this is FFP and we are the prime, since the subcontract is between ourselves and the institutions, I wonder if are in fact able to mandate a lessor %.
  4. The Yes and No answer is unfortunately the one we also are contemplating. The subcontractors are universities and larger institutions, so they have a NICRA and will surely push back, but we want to be able to say that the 10% is mandated. We are awarding FFP subcontracts since as the prime, we were initially awarded a FFP. So basically from a compliance standpoint, it challenging to understand the Indirect Rate requirement since the project is FFP. We are technically not going to do any financial reporting. Thoughts?
  5. Hi, We are a Prime on a FDA IDIQ FFP Award. We are going to subcontract out to several dozen institutions. Since this the prime is FFP, do the subcontractors have the right to charge their full indirect rate? Or could we cap that rate at, for example, 10%? Since it is FFP and we do not expect to report back our finances to the government, it seems like we could create the sucontract between us and the entity and there would be no need to include the flow down. Thanks
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