One recommendation from DHHS:

"for all activities performed in facilities not owned by
the institution and to which rent is directlly
allocated to the project (s) the off-campus rate will
apply.  Grants or contracts will not be subject to
more than one indirect cost rate.  If more than 50% of
a project is performed off-campus, the off-campus rate
will apply to the entire project."

Date:          Fri, 12 Mar
1999 16:01:00 -0500 Reply-to:      Research Administration Discussion
List <xxxxxx@HRINET.ORG> From:          "Matthew E. Clark"
<xxxxxx@SYR.EDU> Organization:  Office of Sponsored Programs,
Syracuse University Subject:       when to use off-campus rates To:
 xxxxxx@HRINET.ORG

hello friends,

I've been trying to determine whether there are controlling regulations
or even some guidance on when it is appropriate to apply our negotiated
off-campus F&A rates.  Our rate agreement used to specify that such
rates should be used when the preponderance of the effort is off-campus
AND more than 30 consecutive days of effort are off-campus.  Now that
our rate agreement is silent on that designation, I'm trying to
establish some consistency.

A-110 does not appear to offer anything.  In A-21, Section G.1.b tells
us to consider environmental factors (including, but not limited to the
physical location of the work) which affect the F&A costs that are
applicable.  When establishing a separate F&A cost pool, we're also
supposed to asses the level of administrative support required, the
nature of the facilities or other resources employed, the scientific
disciplines or technical skills involved, the organization arrangements
used, or any combination thereof.

What do others do?  You can respond directly to me if you prefer.

Thanks in advance for your help.

Matthew Clark
Research Administrator
Syracuse University

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University of Connecticut
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