That was the beauty of the Colorado law: unless there was some good reason that could be reasonably linked to one or more of the university’s research, teaching, or service missions, there was no chance to reduce IDC on a project for a for-profit sponsor. Now, even at Colorado (and elsewhere I’ve worked), we would consider reducing or waiving F&A in a limited number of circumstances, such as student design projects, internships or fellowships, projects that primarily benefited students, or small seed projects that we hoped would eventually lead to a larger collaboration (on which we would absolutely charge full F&A).

The thing that really chaps my onion is that if the roles were reversed and we were asking the for-profit entity to do some work for us, they would absolutely, without thinking or batting an eyelid, include not only their overhead costs but also a fee or some other form of profit for themselves in the cost estimate. Yet they yell like a kid getting blood drawn for the first time whenever we do something remotely similar.

Michael Spires, M.A., M.S., CRA
(He/him/his)

Research Development Officer

The Research Office

Oakland University

256 Hannah Hall

244 Meadow Brook Road

Rochester, MI 48309-4451

(248) 370-2708

xxxxxx@oakland.edu

Past President, National Organization of Research Development Professionals

The best way to get in touch with me continues to be via email: I am working a hybrid schedule.

Oakland University resides on the ancestral, traditional, and contemporary lands of the Anishinaabe, known as the Three Fires Confederacy, composed of the Ojibwe, Odawa, and Potawatomi. The land was ceded in the 1807 Treaty of Detroit and makes up southeast Michigan.

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Sent: Monday, October 24, 2022 15:03
To: 'xxxxxx@lists.healthresearch.org' <xxxxxx@lists.healthresearch.org>
Subject: RE: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

I don’t understand why we should ever accept a loss on project from a for-profit entity.

While I understand that there is a desire to get revenue, our federal-negotiated F&A rates already assume cost-sharing (keep in mind that our administrative component is capped at 26%).

Within the University of California system, we have historically accepted reduced IDC from for-profits in narrow situations where it’s support for graduate students or post-docs. As a general rule, if faculty or staff researcher is seeking funding from a for-profit entity, reducing IDC is not an option. Now, our guidance at UC does talk about who we may take into account intellectual property. But, I would say that UC campuses have become firmer in ensuring full-cost recovery from for-profit sponsors over the past decade (I managed our F&A exception process for the UC system for over a decade…I’ve seen lots of these policies and requests to reduce IDC).

I am excited to read about PSU’s approach of adding 5 percent (good for you!). As some point Yale had an approach where the uncapped administrative costs were applied to for-profit sponsors (resulting in a higher F&A rate for-profit sponsors). I believe at some point that Stanford required that PIs cost-share with a back-up fund (i.e. non-sponsored project unrestricted fund) the portion of lost IDC for sponsors other than non-profits with a published policies.

Mike

Michael Joseph Kusiak

Director, Office of Contract & Grant Administration

UC San Diego

xxxxxx@ucsd.edu | ocga.ucsd.edu

FiatLux

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of O'Brien, Maryellen
Sent: Friday, October 21, 2022 9:41 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

Greetings,

There is a section in the UG that specifically states that recipients of federal funds shouldn’t be subsidizing commercial or foreign entities including foreign governments. Universitates will interpret this in various ways depending on the organizational culture. Whatever the university decides on applying their principles it’s important to be consistent in the application of costs as that’s one of the flags auditors look for.

At Penn State lower rates from commercial organizations are not accepted. In fact, PSU charges an additional 5% on top of our NICRA rate.

Maryellen

Maryellen O’Brien

Director, Office of Grants and Contracts

College of Agricultural Sciences

The Pennsylvania State University

University Park, PA. 16803

EMAIL: xxxxxx@psu.edu

From: <xxxxxx@lists.healthresearch.org> on behalf of "Mounce, Doug - mounce at medicine.washington.edu (via resadm-l list)" <xxxxxx@lists.healthresearch.org>
Reply-To: "xxxxxx@lists.healthresearch.org" <xxxxxx@lists.healthresearch.org>
Date: Friday, October 21, 2022 at 12:28 PM
To: "xxxxxx@lists.healthresearch.org" <xxxxxx@lists.healthresearch.org>
Subject: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

So, a couple more thoughts for Friday fun, arguing to accept the lower rate. I began to think, after hearing the words “program guidelines”, that a lower rate with a commercial sponsor could be justified if the program aligns with the institution’s mission. If this supported a training program, for example, or a new curriculum, then I would argue that the collaboration should be supported. In a similar way, if the funds could all go to tuition, or even equipment fabrication, then maybe the rate issue is moot. At our institution, we charge a lower rate for clinical trials, as another example, and, as far as I know, don’t explicitly explain how that rate is calculated except that it supports the mission and attracts patients to consume other services. I’m old enough to remember when that rate was first introduced, and it basically was for commercial competition.

Doug Mounce

~/ https://staff.washington.edu/mounce/

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Lundin, Deborah Lynn
Sent: Thursday, October 20, 2022 12:48 PM
To: xxxxxx@lists.healthresearch.org
Subject: ▲ RE: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

I agree with both Doug and Michael, however, in the most recent instance, the grant program guidelines require a detailed budget.

Deborah

xxxxxx@ecu.edu

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Michael Spires
Sent: Thursday, October 20, 2022 3:15 PM
To: xxxxxx@lists.healthresearch.org
Subject: RE: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

This email originated from outside ECU.

That’s usually our default starting point with for-profit sponsors: Unless they insist on seeing more detail, we give them a bottom-line amount rather than a detailed budget. And if they push, we still prefer just to give categorical numbers (so much is salaries and wages, so much materials, so much other costs, etc.). As you say, they don’t need to know how we plan to spend the money, all they want is the deliverable.

Michael
(He/him/his)

(248) 370-2708

xxxxxx@oakland.edu

The best way to get in touch with me continues to be via email: I am working a hybrid schedule.

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Sent: Thursday, October 20, 2022 14:45
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

Is there a reason not to use a fixed-price agreement? If it’s a commercial sponsor then they don’t need to know how the money is spent to complete the deliverable or how the price for that was established – I mean, are they sharing their profit margins alongside their F&A policy?

Doug Mounce, Grants and Contracts Manager, Cancer Vaccine Institute, 425 787-3340

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Lundin, Deborah Lynn
Sent: Thursday, October 20, 2022 11:18 AM
To: xxxxxx@lists.healthresearch.org
Subject: ▲ RE: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

Thanks, Michael!

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Michael Spires
Sent: Thursday, October 20, 2022 9:42 AM
To: xxxxxx@lists.healthresearch.org
Subject: RE: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

This email originated from outside ECU.

Haven’t run into that before. But my gut says that we’d reject the rate limitation, on the grounds that it’s inappropriate for a non-profit entity (especially a constitutional entity of the state) to be subsidizing a for-profit business. In my days in Colorado we were lucky – there was a state law on the books that specifically prohibited that, so even when a for-profit firm tried, we just had to quote the chapter and verse from the Colorado statutes and that was the end of the discussion. We don’t have such a law here in Michigan, but it might be worth checking to see whether there is one in your state.

Michael Spires, M.A., M.S., CRA
(He/him/his)

Research Development Officer

The Research Office

Oakland University

256 Hannah Hall

244 Meadow Brook Road

Rochester, MI 48309-4451

(248) 370-2708

xxxxxx@oakland.edu

Past President, National Organization of Research Development Professionals

The best way to get in touch with me continues to be via email: I am working a hybrid schedule.

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Lundin, Deborah Lynn
Sent: Thursday, October 20, 2022 9:01
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] For-profit funding sponsors with publicly published F&A rate limitations

Good morning,

Our institution has had a few recent instances in which PIs have found grant programs offered by for-profit entities that have publicly published an F&A rate limitation that is lower than our NICRA.

Our current policy does not allow us to accept a rate lower than our NICRA from a for-profit, and typically we haven’t seen for-profit sponsors publicly publish a rate limitation. We do accept lower rates from non-profits and governmental entities that have published limitations.

We are looking for policies and practices from other public institutions as it pertains to for-profit entity sponsored program opportunities that have a published F&A rate limitation. Do you accept it because it is published? Do you reject it regardless because it is for-profit? Is it case-by-case and what goes into that deliberation?

Thanks in advance for your insights, and happy to talk off-line as well!

Deborah

Deborah Lundin, Ed.D., CRA

Director of Pre-Award Services

Office of Research Administration

East Carolina University

209 East 5^th Street, Office 145

Greenville, NC 27858-1821

Office: 252.328.9477

xxxxxx@ecu.edu

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