Indirect Cost &
Waiver Update
Senior Contract & Grant Officers
Chris Rigney and Lauren Ryan
False Myths & Assumptions
• “Indirect
cost waivers are always approved”
• “Non-federal sponsors do not provide indirect costs”
• “Recoverable indirect costs can be cost shared”
• “Fellowship Programs never have indirect costs”
• “RFP does not discuss indirect costs, so no indirect
costs are allowed”
• “Sponsor ‘prefers’ no indirect costs, so no indirect costs
are allowed”
• “Reduction of indirect costs is favorable to be funded”
Waiver Submission Timeline
• Always request concurrent with proposal timeframe (3 – 5
business days prior to deadline)
• At least 10 business days prior to deadline for prior
determination by UCOP
• Possibility of withdrawal/rebudget in event waiver is denied
by UCOP
Sponsor Policy Back Up
Documentation
• Published Sponsor Indirect Cost Policy
• Website
• RFP/Solicitation
• Public Record
• Sponsor Policy Letter from Authorized Official
• Reviewed on a case-by-case basis
• Policy applied to all recipients of similar standing to University of
California
• Vital Interest Request may be required
F&A Class Waivers
Status Update:
• A thing of the past…
• Don’t assume there is one
• Proposal Submission Timeframe
• Alternative:
• Individual Waiver
• Sponsor Policy
• Vital Interest
F&A Individual Waiver:
For-Profit Sponsors
• General Rule: You may not seek a waiver based on sponsor
policy for for-profit sponsors.
• Exception: University community service, scholars/fellowship
program if:
• Published announcement calling for proposals;
• Intellectual Property rights and similar interests are properly
justified; and
• No specific deliverable other than technical/final and financial
reports.
F&A Individual Waiver:
Campus Vital Interest
• “…vital to [UCI] to the extent that funding the proposed
project at a loss is more important to [UCI] than recovering
the full indirect costs.”
• Difficult to rationalize with current UC Budget
• Only allowed if sponsor does not permit F&A.
• Timeframe: submit justification letter before completing the
budget.
Campus Vital Interest Continued
• Justifications:
• Short-term seed grants that may attract future larger awards
(<$25,000)
• Grants supporting conferences or meetings hosted by UCI
(<$25,000)
• Cases of hardship for a new investigator
• Support for equipment purchases or capital improvements
• Awards for community relations or health care services vital to
the campus
• Fellowships or student support not associated with specific
research projects
Campus Vital Interest Continued
• Justifications - Continued:
• Supplemental funding for student support services that the campus
wishes to provide, e.g., drug and mental health counseling
• Supplemental funding for library holdings, performances, or exhibits
• Contribution of equipment equal or greater in value to the F&A lost
(equipment must be required for performance of the project as it
would be required as part of the direct cost funding and title must
vest in University)
F&A Individual Waiver:
Foreign Governments
• Individual waivers based on sponsor policy are not allowed for
foreign government organizations.
• Alternative:
• Vital Interest Waiver if you submit:
• Published F&A limitation in legislation or policy document; and
• Short memo or e-mail from the PI.