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 from the PI.