Application of On-Campus and Off-Campus F&A Rates – Policy Change July RARA July 21, 2015 July RARA July 21, 2015

Background The UR’s F&A rate agreement negotiated with DHHS specifies an indirect cost rate to be used for research that is conducted on-campus and another rate for research that is conducted off-campus.

Definitions  On-Campus  Research conducted in space owned by the UR and for which the UR is bearing the space costs from UR funds  Includes space/locations where the sponsor is not charged directly for lease cost (rent) but the UR is paying lease costs.  On-Campus  Research conducted in space owned by the UR and for which the UR is bearing the space costs from UR funds  Includes space/locations where the sponsor is not charged directly for lease cost (rent) but the UR is paying lease costs.

Definitions  Off-Campus  Research conducted in space not owned by UR and not otherwise paid for by the UR from UR funds  An external source provides funding, either paying directly for the space, reimbursing the UR for its rent/lease cost, or providing space for research at no charge to UR  Off-Campus  Research conducted in space not owned by UR and not otherwise paid for by the UR from UR funds  An external source provides funding, either paying directly for the space, reimbursing the UR for its rent/lease cost, or providing space for research at no charge to UR

New Policy  Use the rate applicable to the location where the preponderance of time and effort will be expended (e.g., more than 50% of the time and effort).  When more than 50% of UR time and effort is performed on-campus, then the on-campus rate applies.  When more than 50% of UR time and effort is performed off-campus, the off-campus rate applies.  Each contract or award is assigned only one indirect cost rate.  Use the rate applicable to the location where the preponderance of time and effort will be expended (e.g., more than 50% of the time and effort).  When more than 50% of UR time and effort is performed on-campus, then the on-campus rate applies.  When more than 50% of UR time and effort is performed off-campus, the off-campus rate applies.  Each contract or award is assigned only one indirect cost rate.

New Process  Prior to submitting a proposal, the PI, in consultation with Chair, must determine whether the preponderance of University time and effort will occur on-campus or off- campus over the life of the project.  Determine the preponderance of effort by examining the time and effort that the UR project personnel spend working on project activities in on-campus vs. off-campus locations.  Subawards and vendor agreements should not be considered.  Prior to submitting a proposal, the PI, in consultation with Chair, must determine whether the preponderance of University time and effort will occur on-campus or off- campus over the life of the project.  Determine the preponderance of effort by examining the time and effort that the UR project personnel spend working on project activities in on-campus vs. off-campus locations.  Subawards and vendor agreements should not be considered.

Example 1: Project A  Project will last 3 years  PI will spend one summer month in foreign country  Two graduates and one post-doc will each spend 12 months per year on the project, of which one month will be spent in foreign country  Technician will spend 6 months per year on the project Which rate applies? On-Campus or Off-Campus?  Project will last 3 years  PI will spend one summer month in foreign country  Two graduates and one post-doc will each spend 12 months per year on the project, of which one month will be spent in foreign country  Technician will spend 6 months per year on the project Which rate applies? On-Campus or Off-Campus?

Example 1: Project A  Project will last 3 years  PI will spend one summer month in foreign country  Two graduates and one post-doc will each spend 12 months per year on the project, of which one month will be spent in foreign country  Technician will spend 6 months per year on the project Which rate applies? On-Campus or Off-Campus? Answer: On-Campus Rate  Project will last 3 years  PI will spend one summer month in foreign country  Two graduates and one post-doc will each spend 12 months per year on the project, of which one month will be spent in foreign country  Technician will spend 6 months per year on the project Which rate applies? On-Campus or Off-Campus? Answer: On-Campus Rate

Example 2: Project B  Project will last 3 years – 4 months per year – at a national laboratory  PI will spend two summer months, one of which will be at the national laboratory.  Two graduates will each spend 4 months per year at the national laboratory, and two months will be spent at the UR. Which rate applies? On-Campus or Off-Campus?  Project will last 3 years – 4 months per year – at a national laboratory  PI will spend two summer months, one of which will be at the national laboratory.  Two graduates will each spend 4 months per year at the national laboratory, and two months will be spent at the UR. Which rate applies? On-Campus or Off-Campus?

Example 2: Project B  Project will last 3 years – 4 months per year – at a national laboratory  PI will spend two summer months, one of which will be at the national laboratory.  Two graduates will each spend 4 months per year at the national laboratory, and two months will be spent at the UR. Which rate applies? On-Campus or Off-Campus? Answer: Off-Campus Rate  Project will last 3 years – 4 months per year – at a national laboratory  PI will spend two summer months, one of which will be at the national laboratory.  Two graduates will each spend 4 months per year at the national laboratory, and two months will be spent at the UR. Which rate applies? On-Campus or Off-Campus? Answer: Off-Campus Rate

Example 3: Project C  Five year project for mental health interventions for adolescents  UR rents the facility in which the therapy takes place.  An allocation of rent is directly charged to the sponsored project’s account.  The rent was not included in the UR’s most recent F&A proposal submitted to DHHS. Which rate applies? On-Campus or Off-Campus?  Five year project for mental health interventions for adolescents  UR rents the facility in which the therapy takes place.  An allocation of rent is directly charged to the sponsored project’s account.  The rent was not included in the UR’s most recent F&A proposal submitted to DHHS. Which rate applies? On-Campus or Off-Campus?

Example 3: Project C  Five year project for mental health interventions for adolescents  UR rents the facility in which the therapy takes place.  An allocation of rent is directly charged to the sponsored project’s account.  The rent was not included in the UR’s most recent F&A proposal submitted to DHHS. Which rate applies? On-Campus or Off-Campus? Answer: Off-Campus Rate  Five year project for mental health interventions for adolescents  UR rents the facility in which the therapy takes place.  An allocation of rent is directly charged to the sponsored project’s account.  The rent was not included in the UR’s most recent F&A proposal submitted to DHHS. Which rate applies? On-Campus or Off-Campus? Answer: Off-Campus Rate

Effective Date  July 1, 2015  Apply the policy to all new proposals submitted after June 30, 2015  July 1, 2015  Apply the policy to all new proposals submitted after June 30, 2015

Questions