Yesterday, the School Nutrition Association (SNA) submitted comments on the indirect cost study as requested by the Federal Register notice (76 Federal Register 62341) published on October 7, 2011. SNA believes the results of the proposed study and the potential for additional regulatory proposals will go a long way toward identifying a fair and practical solution to this challenging financial problem. Direct costs are manageable and predictable and allow for responsible budgeting. However, indirect costs are not always controllable and predictable making it more difficult to budget properly.

SNA has also suggested the addition of three threshold questions to be added to the indirect cost study. These three questions are: (1) Who is the Respondent?, (2) What is the Time Frame for the Study?, and (3) Can SFAs Challenge or Appeal Indirect Cost Assessments?

The entire letter can be viewed here.