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 %.