Occasionally, we speak with directors at academic genome centers that express their interest in Genohub, yet are unsure whether listing their high throughput sequencing services would in some way be unauthorized under NIH Circular A21. This circular “Establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions”. Of course this directive does not affect all academic genome centers, but there are a substantial number which do receive grant funding from the NIH.
The general concern regarding how Genohub fits into the Circular A21 picture is understandable. The concern can likely be attributed to subsection J.46 which states:
Costs of selling and marketing any products or services of the institution are unallowable (unless allowed under subsection J.1 as allowable public relations costs or under subsection J.38 as allowable proposal costs).
Clearly, it would not be permissible for academic genome centers under Circular A21 to pay a third party to market their sequencing services. For this reason (among others), high throughput sequencing services are completely free to list on the Genohub Next Generation Sequencing Market. There are also currently no provisions whereby sequencing providers are able to pay Genohub for marketing services. Of course Genohub engages in marketing practices which happen to be aligned with the external facing goals of many academic genome centers, namely attracting and offering the best value to researchers with projects involving next generation sequencing. Service providers do benefit from Genohub marketing, albeit at no cost.
Selling, on the other hand, can be viewed as permissible on Genohub under the subsection J.38 exception as an allowable proposal cost. Circular A21, J.38 states:
Proposal costs are the costs of preparing bids or proposals on potential federally and non federally funded sponsored agreements or projects, including the development of data necessary to support the institution’s bids or proposals. Proposal costs of the current accounting period of both successful and unsuccessful bids and proposals normally should be treated as F&A costs and allocated currently to all activities of the institution, and no proposal costs of past accounting periods will be allocable to the current period. However, the institution’s established practices may be to treat proposal costs by some other recognized method. Regardless of the method used, the results obtained may be accepted only if found to be reasonable and equitable.
Under the J.38 exception, Genohub offers the following service at a nominal fee per transaction through Genohub:
“Preparing bids or proposals”: One of the biggest reasons providers list services on Genohub is because they save valuable time and cost preparing bids or proposals. Services and pricing are listed one time only by the provider. Any time a researcher visits and shops for services via the Genohub shopping interface, Genohub instantly and automatically prepares and delivers bids from every NGS provider that meets the minimum search criteria. Of course Genohub only charges a small fee to the provider whose bid is chosen by the researcher.
The time and money saved on proposal costs by using Genohub has freed up resources for academic genome centers to allow them to refocus on their core objectives within their institution, yet fill those needed external sequencing orders to keep the engines running. Time and cost is further reduced as we offer researchers free consultation from our science team that might otherwise be required of the provider. We hope to continue to increase the value we provide to academic genome centers and researchers alike by creating a beautiful, simple, and cost effective next generation sequencing market.
If you have any additional questions on Circular A21 as it relates to Genohub, or have any feedback on how we can improve the services we offer to you, our valued customers, we encourage you to contact us at firstname.lastname@example.org.