We use the following procedure, for the reasons explained.

We exclude subawards from consideration.  They are "outside" the usual
computation of F&A; the F&A earned by us on them is a negotiated "deal" to
cover the administrative costs of issuing and managing the subaward.  About
15 years ago when "F&A on the first $25,000" was negotiated, it Might have
covered these costs; today it certainly does not -- but there's no change
the University community is likely to get accepted!

We include consultants in the total package, and do not consider them
off-campus.  They are paid for as a procured service and that takes lots of
administrative resources.  Sometimes they actually spend some, or even more
time in our facilities.  More important, consultant expenses are very
seldom a large part of an award, and unlikely top be material in
determining on- or off-campus.

So the "package" is all costs other than subawards.  AND, explicitly,
"field work" is NOT off-campus; on campus resources are used quite as much
on that sort of a project as any other.  You may have to define "field
work".  So far we have not had to do so; it seems pretty clear to every one
here.

So, what is the criteria for the "greater than 50%?  We have consistently
used the personnel total as the 100% being divided as on- and off-.  The
personnel effort expended on the projects is the only matter consistently
comparable between projects of the greatly varying nature a larger
institution may have on which we can base this decision.  ("Consistency is
next to Godliness" -- annon. auditor!).  And in terms of where the effort
is expended, we require the department head (dean, in some cases -- weird
differences among schools as to administration!) to certify about what is
on- and what is off- if it is not clear in the project description.  So
this is my major criterion.

We have another little hooker; our F&A agreement also says that if the
agreement is off campus, "performed in facilities not owned by the
institution and to which rent is directly allocated to the projects" -- so
we have to consider if rent is "directly allocated".  If rent is charged to
the sponsor, this is clear.  However, we are getting more projects done in
collaboration with some other organization, who is supplying the space.  So
we insist that such space be counted as third party cost sharing if we are
going to consider it as an off-campus "rented" space.  We then require the
usual third party certification that space was provided, to document the
cost sharing.  So far we have not had to document a value, because we have
considered it "voluntary" but not "voluntary committed" cost sharing in
proposals.

We believe that, if followed consistently, this method is as good, and as
defensible, as any other.

Chuck

At 12:23 PM 9/29/2003 -0400, O'Brien, Maryellen wrote:
>We are re-evaluating how we apportion costs and calculate whether an on- or
>off- campus rate should apply to an application.  The F&A agreement simply
>states that more than 50% mtdc base must be off-campus.
>
>Historically, we have simply taken the MTDC, generally assumed that
>consultant and subgrantee funds (first 25K) would be off-campus and then
>apportioned the remainder of the budget, calculated the 50% and see where we
>ended up.
>
>The following change has been suggested.  All consultant and subgrantee
>costs (including the first 25K) should be removed from the MTDC base BEFORE
>we apportion the costs to on- or off- campus.  This would be a very
>different model than we've used and would dramatically reduce who would
>qualify for and off-campus rate.
>
>Can you share how you handle this calculation and also what you think of the
>alternative method proposed?  Thanks in advance.
>
>
>Maryellen O'Brien
>Assistant Director
>Grant and Contract Administration
>Office of Research and Sponsored Programs
>Rutgers University
>Cook College
>88 Lipman Drive, Room 125
>New Brunswick, NJ  08901
>
>Ph:   732-932-1000, Ext. 567
>Fax:  732-932-8135
>Email:  xxxxxx@orsp.rutgers.edu
>Web:    http://orsp.rutgers.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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