I do feel your analysis is sound. However, the recent Columbia settlement case may bring further discussion to this topic.
It seemed the Government didn’t want the universities to use on-campus rate when the rent was waived by the lessor.
I am wondering how this case will impact the on and off campus definitions at your institutions.
Thanks,
Jing
Jing Liu, CPA
Assistant Director, Sponsored Projects Services
PO Box 210158, Rm 510
Tucson, AZ 85721-0158Tel: 520-626-6442
Fax: 520-626-4137
From: Research Administration List [mailto:xxxxxx@lists.
healthresearch.org ] On Behalf Of Gray, Barbara
Sent: Thursday, November 17, 2016 6:58 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] On-campus vs. Off-campus rates
Beth and everyone,
We took a good look at the wording in our F&A agreement last year—which may differ across institutions--and determined that we had not been interpreting it correctly. Faculty who were collecting samples in the field or collecting data in a K-12 classroom had receive approvals to use the off—campus rate in the past. We now apply the F&A agreement wording quite literally (ours references rent of facilities, with the rent charged as a direct cost plus the >50% of project activities occurring off-campus [presumably in those rented facilities]), and have also developed guidance with examples. I’m attaching our current guidance. With our much more literal interpretation of the language in our F&A agreement, we now have very few projects that qualify for the off-campus rate.
Even with the guidance we provided, I got a question from a faculty member a couple of weeks ago who insisted that his proposed federal project, which will be at least 6 months duration and includes 1.5 months compensation for two individuals, qualifies for the off-campus rate. He made this determination because he is delivering a program in a foreign facility and will pay $100 per day for 10 days for use of the room. The “rent” is only 1% of the total project cost ($100/day, $1,000 total). Using effort as a proxy, we could quickly make the case that 2 weeks in the foreign country in the rented conference room was not >50% of the project activities, but the “rent” thing got me to thinking.
To me, there’s a big difference between entering into a relatively long-term real estate lease agreement to house project activities for the duration of the project where the university has control/responsibility for the property 24/7 vs. reserving and paying for an easily-cancelled room on a very temporary basis for a project event. I don’t think the latter is what the feds intended in their wish to not pay both long-term rental of facilities to house the project and pay the facilities portion of the F&A rate at the same time on the same project. So we considered the “rent” of $1,000 for the temporary use of the conference room as an “incidental” room use fee and applied our on-campus rate to the project because both off-campus requirements were not met. Of course, we did not charge F&A on the $1,000 room rental cost. Based on this experience, I’m now thinking of expanding our guidance to include discussion of property lease vs. temporary room rental.
And, because the definition of off-campus in our F&A agreement is so vague, I’m also thinking of developing an internal tool to help us document our decisions on a case-by-case basis in the future so that we can consistently assess projects and apply what we believe to be the appropriate rate.
So this discussion is serendipitous for us at this time, and I’ll be very curious to see how everyone else is thinking about this. I would particularly appreciate feedback on our guidance—whether you think it’s good or bad. I had no models—this just came out of experience and what I believe the federal intent to be.
Barbara
From: Research Administration List [mailto:xxxxxx@lists.
healthresearch.org ] On Behalf Of Kingsley, Elizabeth
Sent: Wednesday, November 16, 2016 5:55 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] On-campus vs. Off-campus rates
Hi everyone,
We’re taking a look at our on-campus vs. off-campus rate policy. I’ve seen where institutions just base the determination on where the work is being performed. Others require that rent for the space be involved for the off-campus rate to apply. And I’ve also seen institutions base their determination on the budget – if more than 50% goes towards subcontracts, then it is considered off-campus. I’m interested to hear what your respective institutions are doing, especially if it involves clinical trials. Please respond either on this list or directly to me. My email address is below. Links to policies listed online would be a major bonus!
Thanks!
Best,
Beth Kingsley
Senior Grant Analyst, SPARO
Denver Health and Hospital Authority
777 Bannock Street, MC 1925
Denver, CO 80204
(303) 602-7061 (office)
(303) 602-7078 (fax)
How are we doing? Please take a minute to complete a brief customer service survey found at the following link: https://dhharedcap.ucdenver.
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