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Page 1 CRAD F&A Waiver Process Change November 15, 2007
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Page 2 Issues Large amounts of foregone F&A limit institutional capabilities Institutional risk exists due to inconsistent treatment F&A Waiver process needs to be streamlined UMN is more generous with F&A waivers than other top research universities UMN is more generous with F&A waivers than other top research universities
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Page 3 Minnesota Waiver Volume July 2007 – October 2007 (4 month) Total amount waived: $1,875,382 Total # of waiver requests: 76 Dollar value (direct costs)# of waivers$ waived <50K 40$ 346,899 50K - $100K 12$ 166,222 >$100K 16$1,362,262 Federal Projects 26$ 808,190 Non-Federal 19$ 393,680 State 6$ 305,183 Business & Industry 18$ 194,443 Foreign 2$ 26,527 Other 2 $ 148,079
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Page 4 Peer Positions F&A Waivers not granted to for-profits (UC all campuses, Stanford, Michigan, Washington, MIT, Michigan State, Purdue) F&A Waivers not granted to foreign entities (UC all campuses, Stanford, Penn State, MIT, Michigan State, Purdue)
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Page 5 Minnesota F&A Rates are Competitive U of Washington56.0% UC San Diego54.5% UC San Francisco54.0% UC Los Angeles54.0% UC Berkeley53.5% U of Illinois53.0% (UIC at 57%) U of Michigan52.0% U of Minnesota51.0% Ohio State50.0% Wisconsin47.0% (FY08 under negotiation) North Carolina46.0% (FY08 under negotiation)
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Page 6 SPA PI Transfers Non-profits with published policy Special governmental programs Projects which move from off-campus to on-campus. New Strategy (Part 1) F&A Waiver Requests Administrative Waivers Strategic Waivers Regular Waivers Deans Small Project Waiver (<$50K year) Other Reductions above minimums VPR Waivers or reductions below minimums Tracked
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Page 7 Proposed F&A Rate Minimums (awards over $50K direct costs/year) Federal ……………………………… Federally negotiated rate* Foreign government ………………... Federally negotiated rate* For-profit …………………………… 34% State of Minnesota ………………….. 0% (for now) Non-profit/foundations ……...…….. Lower of 10% TDC or published policy Corporate affiliate programs ……….. 10% TDC Industry-funded clinical trials** …… 26% TDC * or as approved by SPA ** sponsor-initiated protocols only
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Page 8 New Strategy (Part 2) Waivers No Longer Available for: Projects that did not receive institutional endorsement prior to submission to Sponsor F&A waivers or reductions of rates negotiated by PIs with Sponsors If reduced F&A is needed in these instances, the Unit must set up a cost-sharing account to pay the difference between the Sponsor-approved rate and the federally negotiated rate or approved minimum for this type of project.
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Page 9 Potential Reasons to Approve Waivers Seed grants which may attract larger awards Hardship for new PI Awards which include equipment or building funds Community relations or library projects Student services projects (or increase funding to pay for students) Capped awards Department committed to undertake the research regardless of external funding (e.g, any dollar gained is better than nothing) Small cost Junior faculty or incoming faculty member Enhance cultural/artistic activities (small projects only) Only available source of funds in an area Strategic partnerships
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Page 10 Potential Reasons to Disapprove Waivers Precedent setting Grounds on which the waiver might be justified to other faculty whose projects carry full overhead Consistency with similar sponsors or programs Large total cost to the University Any IP rights granted to the sponsor Past history of PI requesting waivers Profit-making entities Foreign entities
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Page 11 New Strategy: Part 3 F&A Waiver Process Improvements 1.Administrative waivers and waivers for small projects (less than $50K) will no longer require use of the formal waiver process 2.SPA has created a list of agencies with pre-approved rates (based on policy); proof of agency policy is no longer required to accompany PRFs when submitting to these entities 3.SPA has new “Foregone F&A calculator” to help Deans and SPA better understand and track foregone amountsForegone F&A calculator 4.Waiver requests must be submitted in advance (4 business days for regular waivers, 7 business days for strategic waivers) 5.CRAD will be updated twice yearly on the amount of F&A waived for regular and strategic waivers Waived amounts will not be tracked for small & administrative waivers
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Page 12 Proposal for New Waiver Strategy Rollout Proposed for January 1, 2008 Streamlined waiver approval process implemented Dean’s approval for small waivers implemented SPA endorsement for administrative waivers implemented No waivers granted for proposals submitted without endorsement Reductions for for-profits and foreign governments beyond pre-set minimum level requires VPR approval Other F&A minimums considered “targets” PIs informed that they may not negotiate F&A rates Proposed for January 1, 2009 F&A minimum levels for all categories implemented
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Page 13 Questions?
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