Regulations & Policies

Academic Affairs - Research and Sponsored Programs

I. OBJECTIVE & PURPOSE

This policy sets forth the requirements for the administration and implementation of Facilities and Administrative (F&A) costs (also referred to as indirect costs) and their use at the University of North Florida. This policy is intended to complement the statutory authority provided to the University pursuant to section 1004.22 of the Florida Statutes, and other state or federal statutes, regulations, and laws governing facilities and administrative costs. 

II. STATEMENT OF POLICY

It is the policy of the University of North Florida to recover F&A costs (indirect costs) from each sponsored award at the appropriate full rates approved by its cognizant Federal Government agency, unless the Associate Provost of Faculty & Research, in consultation with the Provost and Vice President for Academic Affairs, has approved an exception. Principal Investigators are not authorized to negotiate indirect cost matters with sponsors.

It is also the policy of the University to reserve the first use of recovered F&A costs to cover the costs of sponsored project administration. The University will use the remaining funds from recovered F&A costs to support and stimulate further research directed at increasing external sponsorship of research, training, and community service.

The authority and responsibility for administration and implementation of this policy are delegated to the Associate Provost of Faculty & Research. This policy will be reviewed every five years to ensure compliance with statute and to review its effectiveness at recovering and using F&A to the benefit of the University.

1. Applicability

   This policy applies to all sponsored agreements (grants, contracts, and other agreements) with federal and non-federal sponsors.

2. Definitions
   1. “Facilities and Administrative (F&A) Costs (or Indirect Costs)” as defined in the federal regulation on the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Office of Management and Budget (OMB) 2 CFR Part 200, are those costs that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a sponsored project, an instructional activity, or any other institutional activity. These costs include general administration, college and departmental administration, sponsored projects administration, building use allowance, equipment use allowance or depreciation, maintenance, and operation of physical plant, library, student services.
   2. “Modified Total Direct Costs” are defined in OMB 2 CFR Part 200 as “all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000.”
   3. “Cognizant Federal Agency” is established by the OMB to simplify relations between Federal grantees and awarding agencies (see 2 CFR 200.19). It provides for a single agency to represent all others in dealing with grantees in common areas. In this case, the cognizant agency reviews and approves grantees’ F&A cost rates. Approved rates must be accepted by other agencies, unless specific program regulations restrict the recovery of F&A costs. The Department of Health and Human Services (HHS) is the current cognizant agency for the University of North Florida.
3. Responsibilities

   This policy requires all University administrators and Principal Investigators to perform sponsored projects on a full cost-recovery basis. Administrators and Principal Investigators are obligated to ask for and recover indirect costs from sponsors. Full cost recovery is necessary to support the University's physical and administrative capacity to perform extramural projects. Specifically:

   1. The Associate Provost of Faculty & Research is responsible for:
      1. Negotiating F&A rates with the cognizant federal agency.
      2. Distributing information regarding new or changes in F&A rates.
      3. Review and approval of all requests for reduction of F&A rates.
      4. Negotiating with funding sponsors on matters of F&A rates.
      5. Developing procedures for distributing recovered F&A costs.
   2. Principal Investigators are responsible for: Using established F&A rates (or approved lower rates where applicable) to budget anticipated project costs. Principal Investigators are not authorized to negotiate F&A rates with sponsors.
   3. The Assistant Vice President of Research is responsible for:
      1. Reviewing individual proposals and awards to determine the applicable F&A rates.
      2. Ensuring that appropriate F&A rates are applied to all proposal budgets.
      3. Recovering F&A costs from individual awards at the approved rates.
      4. Recording F&A costs in the appropriate ledger.
      5. Reviewing individual awards when F&A rates change to identify those awards that should be changed.
      6. Distributing recovered F&A costs in accordance with established procedures.
4. Establishing F&A Rates

   The Associate Provost of Faculty & Research has the authority to negotiate F&A rates on behalf of the University. Rates are negotiated periodically between the university and its designated cognizant federal agency, the U.S. Department of Health and Human Services (HHS), based upon actual cost records maintained by the university. The rate calculation follows the federal rules and regulations that govern grants, contracts, and cooperative agreements. UNF prepares its F&A rate proposal and submits it with supporting materials to its cognizant agency for audit review. F&A rates are negotiated with a representative of HHS and a written agreement is reached and formally approved with appropriate agency and University signatures for implementation. 

   Through negotiations with HHS, F&A rates are established for all types of sponsored projects:

   Neither UNF nor a sponsor can arbitrarily adjust the university’s F&A cost recovery rates. When UNF accepts a project with a reduced F&A rate, it is agreeing to a substantial subsidy of real costs associated with the sponsored activities.

5. Approval of Lower F&A Rates

   The University expects that proposals to external sponsors will include the maximum allowable F&A cost rate in the proposed project budget. Waivers or reduced rates are rarely given, and only in exceptional circumstances.

   The University may approve a lower F&A rate under one of the following conditions:

   1. A non-profit agency/foundation has published rates restricting the payment of facilities and administrative costs to a lower rate.
   2. A federal or state legislation establishing a program, and/or an appropriation act, limits F&A costs.
   3. An agency of the State of Florida has published rate that imposes an F&A recovery limit on programs funded with state funds.
   4. Compensation for the reduction of F&A costs is provided through an administrative allowance as a matter of a funding agency's policy. The allowance will be prorated at the same rate as the F&A distribution.
      

       

      Note that a subsidy of F&A costs for a for-profit/industry partner would constitute a use of public funds for private benefit and would be an improper use of University resources. 

      The Associate Provost of Faculty & Research, in consultation with the Provost, may approve the cost-sharing of project costs, including F&A costs, if it is determined to be in the best interest of the University. In such cases, sponsored projects with voluntarily reduced F&A rates will not be eligible for the distribution of recovered F&A costs.

6. Use of Recovered F&A Costs

   Florida Statute 1004.22 states, inter alia, that the F&A costs recovered from grants and contracts to the university shall "be deposited in the permanent sponsored research development fund… (and) shall be applied to the cost of operating the division of sponsored research," and that "any surplus… shall be used to support other research or sponsored training programs in any area of the university."

   Accordingly, the University will establish appropriate procedures for the use of funds from recovered F&A costs, consistent with the provisions of the Statute. These procedures will minimally ensure that recovered F&A costs will be used to support the operating costs of the Office of Research and Sponsored Programs (ORSP). 

   Remaining recovered F&A costs will be used to incentivize and support University research activities according to procedures proposed by the the Associate Provost of Faculty & Research as developed in consultation with the Deans and with approval of the Provost and Vice President for Academic Affairs and the Vice President for Administration and Finance. 

   In accordance with Florida Statutes 1004.22(5), these funds must be used to support research and other sponsored project activities. This includes administrative support for existing sponsored projects or expenses related to the development of new projects. Other allowable expenses, by account category, include but are not limited to the following:

   • Summer salary for faculty for research effort
   • Supplemental compensation for faculty for research effort
   • Student or OPS wages to assist with research and administrative support of sponsored projects
   • Travel related to professional development or research development
   • Equipment for research
   • Memberships and subscriptions
   • Publication charges
   • Research-related supplies

The use of recovered F&A costs for expenses that are not directly related to University research activity requires the review and recommendation of the Assistant Vice President of Research and the approval of the Associate Provost of Faculty & Research.

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