VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #R010

2. A LLOWABLE E XEMPTIONS

VCOM will apply the appropriate full federally-negotiated F&A cost rate to proposals and agreements for all grants, contracts or other agreements including those with agencies of the Commonwealth. However, there may be valid reasons for VCOM to reduce or waive these F&A costs on certain projects. Such waivers would reflect the trade-off between the need to cover the actual F&A costs against the need for the College to meet other strategic goals. Such exemptions for reduction or waiver are: 1. By law or regulation, a government agency has a reduced F&A rate.

2. A foundation has a public, formal written policy on F&A rate, consistently applied. 3. A corporation has a public, formal written policy on F&A rate, consistently applied.

In addition, consideration will be given to F&A reductions or waivers when these requests are directly associated with the College goals listed below: 1. F&A costs may be reduced or waived when the Provost, Dean and Executive Vice President judges the project to be of exceptional academic merit. 2. F&A costs may be reduced or waived when the Provost, Dean and Executive Vice President deems this one of the costs appropriate for the College to contribute to meet the published policy of a governmental or non-profit sponsor that the recipient must share in the total cost of the project (cost sharing). In such a case, the VCOM Cost Share Approval Form must be signed by the Provost, Dean and Executive Vice President. 3. F&A costs may be reduced or waived when the Provost, Dean and Executive Vice President judges that the inclusion of full F&A costs would make the College’s proposal not cost competitive.

3. VCOM F UNDED P ROJECTS

VCOM does not pay F&A costs on any internally-sponsored projects and/or seed projects funded by VCOM or any of its departments. VCOM’s seed funds do not include funds to cover institutional indirect costs.

4. P ROCEDURES

Those governmental and non-profit award programs that limit or prohibit F&A cost recovery state such limits in their submission guidelines and/or applications. An investigator planning a submission to such a program must submit to the ORA the guideline / application form of the agency that clearly states such limiting or prohibition of F&A cost recovery. No further internal documentation of the approved exemption will be needed. If an investigator of any grant desires a reduction or waiver of F&A costs based on the academic merit of the project or the non-cost compe titiveness of the project’s budget, the investigator must prepare a written request for such a reduction. This request must include a statement of the amount of F&A costs requested to be foregone and the justification for doing so, and it must be forwarded on to the ORA. Such a request will be noted by the ORA and submitted to the Provost, Dean and Executive Vice President for approval, as well as to the Associate Dean for Clinical Research and the Associate Dean for Biomedical Research. The request and approving signatures of the ORA Director and the Provost, Dean and Executive Vice President will be retained in the project file as documentation of the approved exemption. If an investigator of any grant desires a reduction or waiver of F&A costs to meet cost sharing requirements, the investigator must inform the ORA and complete a cost share approval form. This form will be forwarded for approval to the Provost, Dean and Executive Vice President. The request and approving signature of the Provost, Dean and Executive Vice President and the applicable Associate Dean (Clinical or Biomedical Research) will be retained in the project file as documentation of the approved exemption. The ORA and the Provost, Dean and Executive Vice President may define in writing a specific category of grant that will receive special F&A cost rates. This categorical exemption will be made available on the ORA website, and no further documentation will be necessary.

Facilities and Administrative Cost Recovery Policy

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