First read the definition of off-campus in your federal rate
agreement. For example, ours includes the words "and to which rent is
directly allocated to the project(s)". Thus if there is no rent budgeted,
cannot use off-campus rate. Note "allocated to project) -- this means part
of the total project cost of the project, not necessarily just the sponsor
budget. We have a number of projects conducted largely in locations owned
by others, and if the third party cost sharing specifies provision of space
in a way that we can evaluate the value (comparative rents), it can be
off-campus.
Second review with your F&A negotiators what spaces go into the facilities
pool. Never let activities in such spaces have the off-campus rate. For
some institutions this may be locations "owned" only; for others it may
include spaces leased, also. Urban institutions are more likely to have
the latter.
Third, be specific that "field work" is not misinterpreted as "off-campus".
Almost all F&A rate agreements provide that a single rate will apply for
any single agreement. Generally the key here is "more than 50% is
performed". Define a consistent way to measure that. We use the % of
personnel cost in the sponsor budget, reasoning that this is a reliable
measure of "performed". (Get the PI to specify in a memo, concurred by the
chair, if it is not clear in the proposal.) I'd suggest not relying on %
effort, because that is generally more variable in the conduct of a project
than personnel cost budgeted. This division may be examined when the
sponsor reviews the budget, but not often examined on audit. If you have a
reasonable measure consistently applied, an auditor can be satisfied.
Chuck
At 05:10 PM 2/10/2003 -0500, you wrote:
>Good Afternoon,
>
>How does your organization determine when to use off-campus F&A rates in
>sponsored project budgets? Do certain conditions have to be met? For
>example, does the budget need to include funds to pay rent? What
>percentage of the research or sponsored activity has to be done off
>campus in order for the off-campus rate to apply to the entire budget?
>
>If you could, please indicate your F&A base when you reply.
>
>Thanks!
>
>Lori Messer, Director
>Research & Sponsored Programs
>Wake Forest University
>P.O. Box 7528 Reynolda Station
>Winston-Salem, NC 27109
>(336) 758-5888
>(336) 758-1959 fax
>xxxxxx@wfu.edu
>
>
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Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Commonwealth University
PO BOX 980568
Richmond, VA 23298-0568
Express Delivery Only:
Biotech One, Suite 113
Virginia Biotechnology Research Park
800 East Leigh Street
Richmond, VA 23219
Voice: 804-828-6772
Fax 804-828-2521
OFFICE e-mail xxxxxx@VCU.EDU
Personal e-mail xxxxxx@vcu.edu
http://www.research.vcu.edu/ospa.htm
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