For your first question, the answer may depend on who the sponsor is. While in general you have the right to voluntarily waive or reduce your IDC recovery, at least NSF will see that as voluntary committed cost sharing, which is prohibited under its guidelines and policies. So you’ll almost certainly have to switch rates for any NSF-funded projects. No potential audit issues otherwise, but you’ll take a hit in your next IDC rate negotiations – every dollar you could’ve taken but didn’t factors into the rate-setting algorithm.
To your second question, yes, I think I would be inclined, at least where doing so wouldn’t constitute an insuperable obstacle to completing the proposed scope, or where the project was just about to end anyway and mostly the funds were already gone, to apply the on-campus rate to all the transferred projects. The off-campus rate only covers the administrative part of “facilities and administrative costs.” Once those projects come back on campus, they’re relying on all that infrastructure that was covered through other means (probably the rental agreement, at least for leased space) – and they should be contributing their fair share to those costs. Especially since costs might go up now that there’s more demand on that infrastructure.
Michael Spires, M.A., M.S., CRA
(He/him/his)
Research Development Officer, Sciences
The Research Office
Oakland University
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From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Jesse Szeto
Sent: Friday, May 01, 2020 14:02
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Project moves from off-campus to on-campus, do we HAVE to use the on-campus F&A rate?
We are in the process of moving some faculty and their projects from an off-campus location to an on-campus location. What would you recommend that we do for the F&A rate for their grants?
My thoughts:
Category 1 - For all existing grants with a signed agreement, I am planning to keep the F&A rate the same. That is, we will continue to charge the off-campus F&A rate even though we are entitled to charge the on-campus F&A rate.
Category 2 - For all proposals, I am planning to change the F&A rate to on-campus.
My questions:
1. For Category 1, it is OK for us to charge a lower IDC rate than what we are entitled on a federal grant, is that correct? No potential audit issue there, right?
2. Would you do things differently?
Thanks,
Jesse
--
Jesse J.K. Szeto | 司徒祖傑
Senior Director
Office of Research Services (ORS), Main Campus
Georgetown University
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E-mail: xxxxxx@georgetown.edu
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