Back in the day I used both on and off campus accounts with different rates as a matter of routine. All faculty and researchers were charged to the on-campus account unless they were on leave or assigned to the off-campus facility by their dean. The materials and services were charged to the account where the person ordering was charged. It takes a bit of effort to keep track of this, but it's the best way we could come with at the time to make sure that researchers wouldn't attempt to take advantage of the lowered off-campus F&A rate. Not that they'd ever do that! A good policy statement should help out a lot in terms of defining what constitutes off-campus research. One school defined it as off the main campus in non-university facilities. Another extreme was over 50% effort occurring more than 50 miles from campus in a facility not owned by the university for more than one year. If it failed one or more of these, it was on-campus full F&A rate. Greg Schmidt GKS Consulting, LLC 703-346-5696 This information is intended for the named recipient only and may contain confidential/privileged material. Review, dissemination, or use of, or reliance on this information by others is prohibited. If received in error, please contact xxxxxx@verizon.net and delete. -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Tamara Hatch Sent: Thursday, April 16, 2009 12:38 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] IDC on non-federal contracts - any flexibility based on regs? Hello Fellow Research Administrators- I’m following this dialogue about the application of F&A rates to non-federal sponsors with great interest and have a question for your expert consideration & guidance. We are also a S&W base institution, a PUI, and we’re having difficulty with a PI who wants us to come up with a hybrid rate of our NICRA to apply to activities which will take place on vs. off campus within the same funded project. Our policy has been at the time of budget projection to assess whether 60% of the total project activities will take place either on campus or off campus and based on that determination, either apply the higher rate (45% S&W) or the lower off campus rate (18.5% S&W) to the entire project. We do not have the capability to track salaries and wages as to where they physically occurred when calculating the F&A recovery post-award. Our practice is to apply our NICRA rates to all projects whether the sponsors are federal or non-federal. We’ve offered the PI the option of setting up separate cost accounts for on-campus phases of the project vs off-campus phases but the PI is not interested in this approach because it is administratively inconvenient. Can any of you point to regulations or provide experiences which would help us to establish a fair and consistent F&A rate which differs from our NICRA to non-federal sponsors? We are not comfortable establishing a precedent for charging F&A to sponsors which is not specified by our NICRA, especially when it may be less in some cases than what we’d charge the feds, but it seems that the door is open to use the flexibility of assigning a higher rate. Feel free to contact me off-line if you wish at (540) 568-2350. I apologize for this lengthy post, but truly appreciate and admire your creative input to help us stay compliant. Tamara T. Hatch, CRA Associate Director Sponsored Programs Administration ________________________________________ From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Rene Hearns Sent: Thursday, April 02, 2009 5:18 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] IDC on contracts - salary/wage base institutions Kris, Both of my prior institutions established a flat rate for other entities not the federal government. My immediate past institution used 20% of total direct costs unless limited in writing by the sponsor. Hope that helps. r ------------------------------ Rene Hearns, PhD (cand), MPA, CRA Director, Office of Sponsored Programs and Research University of Louisiana at Monroe 700 University Avenue LIB 211 Monroe, LA 71209-3925 T: 318.342.1039 F: 318.342.1479 xxxxxx@ulm.edu Dissertation Topic: Evaluating the impact of engaged learning on direct and indirect citizen participation. From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Kris Wolff Sent: Thursday, April 02, 2009 11:47 AM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] IDC on contracts - salary/wage base institutions Hi Rene, On page 1 of our DHHS agreement it states: “BASE: Direct salaries and wages including vacation, holiday, sick pay and other paid absences but excluding all other fringe benefits.” On page 2 of our agreement it states: “(1) Treatment of Fringe Benefits: All fringe benefits except vacation, holiday and sick pay are treated as indirect costs.” Since you have previous experience with S&W, do you recall what rate those institutions used with industry contracts? That would be helpful! Thanks! Kris ________________________________________ From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Rene Hearns Sent: Thursday, April 02, 2009 12:32 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] IDC on contracts - salary/wage base institutions Kris, My previous experience with S&W was that fringe was not included in the calculation. You may want to recheck your negotiated rate agreement. ------------------------------ Rene Hearns, PhD (cand), MPA, CRA Director, Office of Sponsored Programs and Research University of Louisiana at Monroe 700 University Avenue LIB 211 Monroe, LA 71209-3925 T: 318.342.1039 F: 318.342.1479 xxxxxx@ulm.edu Dissertation Topic: Evaluating the impact of engaged learning on direct and indirect citizen participation. From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Kris Wolff Sent: Thursday, April 02, 2009 10:46 AM To: xxxxxx@hrinet.org Subject: [RESADM-L] IDC on contracts - salary/wage base institutions Hi Everyone, Our negotiated IDC rate is based on salaries/wages only, and our fringe is included in that. I’m curious what other non-MTDC institutes charge as indirect costs when they are negotiating industry contracts. I’m also leaning toward including our fringe as a direct cost in those sorts of contracts, does that seem reasonable? Feel free to email me directly at xxxxxx@fordham.edu. Thank you! Kris ------------------------------------------------------- Kris Wolff, MA, CRA Grants Officer Office of Sponsored Programs Rose Hill campus, ADM 221 718-817-4086 http://www.fordham.edu/osp ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
