07/15 RARA Presentation

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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
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