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

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-----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

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======================================================================
 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")
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