Supersedes: GIM 13, November 17, 2011
This GIM is updated to conform to the Federal Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) effective December 26, 2014. This GIM applies to new awards and new funding for existing awards received on or after Dec 26, 2014.
For awards in existence prior to December 26, 2014 that have not received supplemental funding or are not otherwise subject to the Federal Uniform Guidance per sponsoring agency award terms and conditions, please refer to the Archived GIM 13.
This policy documents Facilities and Administrative (F&A) rates applicable to sponsored programs.
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Chapter I, Chapter II, Part 200, Uniform Guidance) includes principles for determining costs applicable to grants, contracts, and other agreements between the Federal government and non-federal entities, including higher education institutions. The Uniform Guidance defines criteria for determining both direct and F&A costs. In addition, the Uniform Guidance establishes a mechanism for higher education institutions to calculate, negotiate, and recover F&A costs from federal and other sponsors.
Direct costs are those costs that can be identified specifically with a particular sponsored project with a relatively high degree of accuracy. F&A costs are those costs incurred for a common or joint purpose benefitting more than one cost objective that cannot be readily assigned to a particular sponsored project. F&A costs are also referred to as "indirect costs."
Management Accounting and Analysis (MAA), a division of Financial Management, periodically develops and negotiates the University's F&A proposal with the Department of Health and Human Services, Division of Cost Allocation (HHS-DCA). F&A cost rates are based on the University's actual operating costs. Using the Uniform Guidance, the University assesses its F&A costs on a regular basis and allocates these costs to different activities, such as research or teaching, proportionate to the benefit provided. Once all F&A costs are determined, the University then determines the portion of those costs that are attributable to research. This information is reviewed by the Federal government and F&A cost rates are negotiated every 4 to 5 years. This becomes the F&A Rate Agreement.
Principal Investigators, Research Personnel, Research Administration Personnel, Academic Unit Chair, Dean's Office, eGC1 Reviewers, Office of Sponsored Programs, Grant and Contract Accounting, Management Accounting and Analysis, Assistant Vice Provost for Research, Office of Planning and Budgeting.
The University calculates and includes F&A costs in all sponsored program budgets as set out in the F&A Rate Agreement, unless one of the following applies:
|Affiliated organizations||When the University has an established agreement in place with an affiliated organization that determines the rate applicable to the funding, the University will accept that rate.|
|Federal sponsors (including federal flow-through, no matter the pass-through entity type)||Since all Federal awarding agencies must accept negotiated rates and all pass-through entities must honor negotiated rates, the University will accept a rate cap only if the rate is limited by Federal statute or regulation, or when approved by a Federal awarding agency head or delegate based on documented justification, after proper notification to the Federal Office of Management and Budget. Such criteria used to cap the rate must be publicly available.|
|Non-Federal government sponsors||The University will accept a rate cap if the non-federal government sponsor has a bona fide policy as evidenced by reference to an approved F&A rate established by statute, in the official program announcement, or on the sponsor-approved application form.|
|Industry Sponsored Clinical Trials||Industry sponsored clinical trials have a University established rate of 27% TDC.|
|Non-profit sponsors||The University will accept a rate cap if the non-profit entity has a published policy as evidenced by reference on the non-profit's website, in the official program announcement, or on the sponsor-approved application forms. Alternatively, if the entity is listed on the non-federal sponsor F&A rate table, the rate listed will be accepted as the rate cap for that sponsor, unless otherwise specified by that sponsor by policy, website, program announcement or application form.|
|Research Affiliate Programs (RAPS)||20% of membership fees are allocated to F&A. Annual membership fees are inclusive of F&A. RAPS Members must pay full F&A for all other non-qualifying sponsored projects.|
|A single project with a total cost of $5,000 or less over the life of the award||The University will accept a rate cap if it is for a single project with a total cost of $5,000 or less over the life of the award. This exception does not apply to multiple awards of $5,000 or less from the same sponsor for the same project nor does it apply to industry sponsors.|
|Transfer from another institution with a lower F&A rate on established project||The University will accept a lower rate when a PI transfers his/her project to the University of Washington from another institution, and the rate awarded for the project is lower than UW's established F&A rate. This does not apply to requests for additional funding from the sponsor for the project, once the project is transferred.|
|Research storage, managed servers and cloud services provided by UW Information Technology (IT) or via vendor contract managed by UW IT||UW Information Technology (UW-IT) offers large scale storage services, compute services (managed physical and virtual servers), and related infrastructure and platform services, through a combination of on-campus facilities and contracts with cloud service vendors such as Microsoft and Amazon. These costs are identified under UW object code 03-04 (Rsrch Strg, Compt&Cloud) and are exempt from F&A.|
|Fabrication of Equipment||Equipment that is being fabricated for use at the University has the cost of fabrication broken into individual direct costs towards the fabrication, and can include salaries and supplies. These direct costs are excluded from the base calculation when applying F&A. Other costs associated with the project that are not costs towards equipment fabrication are charged F&A per the rate agreement. Costs associated with equipment fabrication when the equipment is for delivery to an external entity are charged F&A at the rate set out in the F&A Rate Agreement. More information can be found at the Equipment Inventory Office's website.|
|Subawards to another entity||The University will honor an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal government for the activity proposed. If no such rate exists, the University will include a de minimis indirect cost rate of 10% of MTDC or we will negotiate an appropriate rate. Please see GIM 7 for more information.|
The University may charge an F&A rate that is higher than the applicable Federal rate for a sponsored program funded by a for-profit entity, and in all cases, will not charge F&A rates that are lower than those applied to Federally sponsored programs.
Any deviation below the rate in the F&A Rate Agreement or not listed under Special Cases will require advanced approval of an F&A waiver by the Office of Sponsored Programs. This approval will only be granted in limited situations. An application for an F&A waiver must be made in the form required by the Office of Sponsored Programs and included with the sponsored project proposal materials.
F&A rates are applied to the cost base associated with the location and type of project as specified in the F&A Rate Agreement unless a sponsor has a stated cost base in the official program announcement. When a non-federal sponsor's policy does not specify a base type, the Total Direct Costs (TDC) cost base applies.
The Table of F&A Rates and Base Types for the University of Washington provides a summary of the negotiated rates within the current F&A Rate Agreement for the University as well as other established rates for some specialized studies and agreements.
In order to implement the University policy on F&A rates, it is necessary to follow the procedures and guidance outlined in this section.
|Grant and Contract Support of University Activities||University of Washington Executive Order #34|
|University of Washington Facilities and Administrative (F&A) Rate Agreement||F&A Rate Agreement|
|Federal Cost Principles||Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Chapter I, Chapter II, Part 200, Uniform Guidance|
|University's Costing Policy||GIM 23|
|Primary Office Contact||OSPfirstname.lastname@example.org||206-543-4043|
|F&A Cost Calculation||MAA|
|Responsible University Office||Policy Owner|
|Office of Sponsored Programs||Assistant Vice Provost for Research, as delegated by the Vice Provost for Research|
This policy is reviewed by the Office of Sponsored Programs at time of approval of new F&A rate agreement and as necessary to reflect changes in Federal regulation or University policies.