We also had a rate increase from one fiscal year to another. The following guidance was provided to our faculty:

 

When a proposed budget period will cross FSU’s FY14 and FY15, the following options may be used when calculating F&A:

 

OPTION 1: Calculate F&A for that budget period on a prorated basis based on the number of months in each fiscal year (FY14 and FY15). For example, the budget period proposed is 01/01/14 through 12/31/14. The first 6 months will be calculated using 51.3%; the last 6 months at 52%.

OPTION 2: Calculate F&A for that budget period on a prorated basis based on the amount of expenditures that are estimated for FY14 vs. FY15. For example, the budget period proposed is 01/01/14 through 12/31/14. Out of a total of $100,000 proposed for the budget period, $75,000 is expected to be spent during the period 01/01/14 through 06/30/14, and $25,000 is expected to be spent during the period 07/01/14 and 12/31/14. The $75,000 will include F&A at 51.3%; the $25,000 at 52%.

OPTION 3: Calculate F&A at 51.3% for the entire budget period if the majority of the period falls within FY14, or at 52% for the entire budget period if the majority of the period falls within FY15.

 

The following budget justification should be included in the proposal:

FSU’s negotiated F&A rate is 51.3% for the period 7/1/12-6/30/14, and 52.0% for the period 7/1/14-6/30/16. The award will be charged the actual F&A rate in effect at the time of expenditure.

 

 

 

 

Until your new rate takes effect, you should use the current one. But once you have a formal, signed agreement for the new rates, I’d start building them into proposals as appropriate.

 

The applicable federal guidance is in OMB Circular A-21, Section G.7, or Appendix III to Part 200, Section C.7 of the new uniform guidance (2 CFR 200):

 

Federal agencies shall use the negotiated rates for F&A costs in effect at the time of the initial award throughout the life of the sponsored agreement. (A-21)

 

Federal agencies must use the negotiated rates except as provided in paragraph (e) of §200.414 Indirect (F&A) costs, must paragraph (b)(1) for indirect (F&A) costs in effect at the time of the initial award throughout the life of the Federal award. (2 CFR 200, Appendix III, Section C.7: I hope they fix the grammar here before it takes effect!)

 

Since the guidance clearly says “rates,” you’d only need to budget according to the schedule in your rate agreement.

 

 

Michael Spires, M.A., M.S.

Senior Proposal Analyst

Office of Contracts and Grants

xxxxxx@colorado.edu

3100 Marine Street, Room 475 | 572 UCB | Boulder, CO 80309-0572

Ph: 303.492.6646 | Fx: 303.492.6421

 

 

 

 

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