Guidelines for facilities and administrative cost recovery

Facilities and administrative cost recovery policy

Full recovery principle

pinpoints from a to b As required by the Commonwealth Accounting Policies and Procedures Manual, VCU will apply the full federally negotiated F&A cost rate(s) to all grants, contracts or other agreements proposed and/or accepted, including those with other agencies and instrumentalities of the commonwealth, unless exempted as described below.

Limitation of total project costs by the sponsor is not justification for less than full F&A recovery. Projects should be scoped and costed to meet the sponsor limitation with applicable negotiated rate applied.

Project costs shall not be quoted to potential sponsors with less than full F&A costs except in accordance with the procedures described in these guidelines.

Cost recovery exemption

Extraordinary or unusual circumstances may lead VCU to apply one of the exemptions listed below if the Vice President for Research and Innovation (or designee) deems the proposed activity to have significant benefit to the university based on submission of F&A Exemption Request form bearing all required signatures.

Sponsor type	Published F&A recovery limit	Academic merit	Required cost share/match
Government and/or non-Profit, including other Commonwealth agencies and instrumentalities
Corporate

What F&A rate do I use?

The appropriate rate will depend on the predominant nature and primary performance site of design, conduct and reporting of the project. While some programs may have statutory or regulatory limits on F&A recovery, that does not change the nature of the project.

Primarily sourced from 2 CFR 200, Appendix III, also known as Uniform Guidance “Indirect (F&A) costs identification and assignment, and rate determination for institutions of higher education (IHEs)”:

Rate	Definition	Performance site
Organized research	Organized research means all research and development activities of an institution that are separately budgeted and accounted for. This definition includes all research and development activities that are sponsored by Federal and non-Federal agencies and organizations. This term includes activities involving the training of individuals in research techniques (commonly called research training) where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instruction function.	On-campus: For all activities where 50% or more of the design, conduct and reporting are performed in facilities OWNED by the institution.
		Off-campus: For all activities where 50% or less of the design, conduct and reporting are performed in facilities NOT OWNED by the institution and to which rent is directly allocated to the project. Field work per se is not a qualification.
Instruction	Instruction means the teaching and training activities of an institution. Except for research training as described above, this term includes all teaching and training activities, whether they are credit or non-credit courses. Sponsored instruction and training means specific instructional or training activity established by grant, contract or cooperative agreement.	On-campus: For all activities where 50% or more of the design, conduct and reporting are performed in facilities OWNED by the institution.
		Off-campus: For all activities where 50% or less of the design, conduct and reporting are performed in facilities NOT OWNED by the institution and to which rent is directly allocated to the project. Field work per se is not a qualification.
Other	Means programs and projects financed by Federal and non-Federal agencies and organizations which involve the performance of work other than instruction and organized research. Examples of such programs and projects are health service projects and community service programs and studies, and technical and service programs.	On-campus: For all activities where 50% or more of the design, conduct and reporting are performed in facilities OWNED by the institution.
		Off-campus: For all activities where 50% or less of the design, conduct and reporting are performed in facilities NOT OWNED by the institution and to which rent is directly allocated to the project. Field work per se is not a qualification.
Training	Certain Federal agencies such as DHHS and the Department of Education are authorized by OMB to limit F&A to 8% for programs they identify as “training,” and as specified in the program announcement.
Commonwealth agency	Should be selected when the funding source is the Commonwealth of Virginia but not when federal funds are flowing through a state agency.
Industry-sponsored clinical trial/research	The industry-sponsored and investigator-initiated clinical trials/research rate is 30% of total direct costs. Such studies include Phase I-IV human studies and meet the definition of clinical trial/research.