June 8, 2015

F&A Cost Recovery: On- and Off-Campus Rates

Good morning,

The Office of Sponsored Programs Administration (OSPA) maintains internal policies and procedures for recovery of facilities and administrative (F&A) costs consistent with System-wide BPM-203, F&A Cost Recovery (Grants & Contracts).

In collaboration with MU campus and UM System partners, OSPA has developed an addition to the F&A policy* to provide clear and consistent guidance for determining on- or off-campus classification of sponsored activities. There is also clarification regarding the applicable rates for clinical trials.

The guidance is published to the OSPA website as an addition to the F&A Cost Recovery policy. Should you have questions about the applicability of this policy to current or anticipated projects, please contact OSPA.    


Craig David
Director
Authorized Signer, Grants and Contracts
Phone: 573.882.9570 | Fax: 573.884.4078 | davidcr@missouri.edu
University of Missouri | Sponsored Programs | 310 Jesse Hall, Columbia, MO 65211





On- and Off-Campus Rates
Definitions
The on- or off-campus classification is solely for the purpose of applying the correct F&A (indirect cost) rate.

Off-campus project: A project located in leased space that is sufficiently far removed from the campus to prohibit the normal use of University facilities (i.e., telephone, mail, network, and other support services) and the lease is a direct charge to the project
On-campus project: (1) A project located within a reasonable distance of University facilities or (2) a project located in leased space where the project is not charged directly for the lease cost and the lease is a part of the University's F&A (indirect cost) rate

Any deviation from these definitions in determining the applicable rate must be approved by the Director of the Office of Sponsored Programs Administration (OSPA).

Note: Agreements with the Truman Memorial Veterans’ Hospital (VA) are exempt from the off-campus requirement to be sufficiently far removed from the campus due to the nature of the VA’s relationship with the University. 

Projects Conducted Partially Off Campus
Grant or Contract Award (Annual Level) of $100,000 or Greater in Modified Total Direct Costs. Projects with total annual modified total direct costs (MTDC) of $100,000 or more which are partially performed off campus are prorated between on-campus and off-campus components for F&A rate application purposes in instances where the lesser component is greater than 20% of the MTDC of the project. If 80% or greater of the MTDC is determined to be on-campus costs, the entire project is charged the on-campus rate. If 80% or greater of the MTDC is determined to be off-campus costs, the entire project is charged the off-campus rate.

Grant or Contract Award (Annual Level) Under $100,000 in Modified Total Direct Costs. Projects with total annual MTDC of $100,000 or less which are partially performed off campus are not apportioned between their on-campus and off-campus components for F&A rate purposes. If 50% or more of the project’s MTDC are to be expended on campus, the entire project is charged the on-campus F&A rate. If more than 50% of MTDC are to be expended off campus, the entire project is charged the off-campus F&A rate.

Clinical Trials
The University utilizes a special 26% TDC (total direct costs) clinical trials F&A rate that is in keeping with rates employed by other research universities. Financial support must be provided by a private entity, including pharmaceutical companies, interest groups, or charities. The University’s federally-negotiated rates apply to all federally-funded clinical trials, whether the funds are awarded directly from the sponsor or flow through an intermediary sponsor.


When a commercial or industrial firm requires rights in data to the exclusion of the University and/or claims ownership rights to intellectual property developed by the University under a clinical trial project, F&A costs must be charged at not less than the clinical trials rate plus five (5) percent.