Application of On-Campus and Off-Campus F&A Rates – Policy Change July RARA July 21, 2015 Background The UR’s F&A rate agreement negotiated with DHHS specifies an indirect cost rate to be used for research that is conducted on-campus and another rate for research that is conducted off-campus. Definitions On-Campus Research conducted in space owned by the UR and for which the UR is bearing the space costs from UR funds Includes space/locations where the sponsor is not charged directly for lease cost (rent) but the UR is paying lease costs. Definitions Off-Campus Research conducted in space not owned by UR and not otherwise paid for by the UR from UR funds An external source provides funding, either paying directly for the space, reimbursing the UR for its rent/lease cost, or providing space for research at no charge to UR New Policy Use the rate applicable to the location where the preponderance of time and effort will be expended (e.g., more than 50% of the time and effort). When more than 50% of UR time and effort is performed on-campus, then the on-campus rate applies. When more than 50% of UR time and effort is performed off-campus, the off-campus rate applies. Each contract or award is assigned only one indirect cost rate. New Process Prior to submitting a proposal, the PI, in consultation with Chair, must determine whether the preponderance of University time and effort will occur on-campus or offcampus over the life of the project. Determine the preponderance of effort by examining the time and effort that the UR project personnel spend working on project activities in on-campus vs. off-campus locations. Subawards and vendor agreements should not be considered. Example 1: Project A Project will last 3 years PI will spend one summer month in foreign country Two graduates and one post-doc will each spend 12 months per year on the project, of which one month will be spent in foreign country Technician will spend 6 months per year on the project Which rate applies? On-Campus or Off-Campus? Example 1: Project A Project will last 3 years PI will spend one summer month in foreign country Two graduates and one post-doc will each spend 12 months per year on the project, of which one month will be spent in foreign country Technician will spend 6 months per year on the project Which rate applies? On-Campus or Off-Campus? Answer: On-Campus Rate Example 2: Project B Project will last 3 years – 4 months per year – at a national laboratory PI will spend two summer months, one of which will be at the national laboratory. Two graduates will each spend 4 months per year at the national laboratory, and two months will be spent at the UR. Which rate applies? On-Campus or Off-Campus? Example 2: Project B Project will last 3 years – 4 months per year – at a national laboratory PI will spend two summer months, one of which will be at the national laboratory. Two graduates will each spend 4 months per year at the national laboratory, and two months will be spent at the UR. Which rate applies? On-Campus or Off-Campus? Answer: Off-Campus Rate Example 3: Project C Five year project for mental health interventions for adolescents UR rents the facility in which the therapy takes place. An allocation of rent is directly charged to the sponsored project’s account. The rent was not included in the UR’s most recent F&A proposal submitted to DHHS. Which rate applies? On-Campus or Off-Campus? Example 3: Project C Five year project for mental health interventions for adolescents UR rents the facility in which the therapy takes place. An allocation of rent is directly charged to the sponsored project’s account. The rent was not included in the UR’s most recent F&A proposal submitted to DHHS. Which rate applies? On-Campus or Off-Campus? Answer: Off-Campus Rate Effective Date July 1, 2015 Apply the policy to all new proposals submitted after June 30, 2015 Questions