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Research CCHIP #021

CLARIFICATION OR CHANGE IN PROCEDURE (CCHIP)

Assignment of Indirect Costs (F&A) Rates

OVERVIEW

The recovery of Indirect Costs makes research at the ¹ú²ú¶ÌÊÓƵ possible by funding the labs, equipment, infrastructure, and the administrative and compliance operations necessary to be the best stewards of sponsored research. In addition, Indirect Costs fund internal awards, and the initiatives of each college and department through distribution to the respective colleges.

¹ú²ú¶ÌÊÓƵseeks to recover all indirect costs allowed by a sponsor in order to fund research operations at the ¹ú²ú¶ÌÊÓƵ. Recovering less than the maximum allowable indirect cost rate disadvantages the University research enterprise and devalues the true cost of conducting organized research. For that reason, ¹ú²ú¶ÌÊÓƵrequires the full recovery of indirect costs whenever possible as outlined in this CCHIP.

DEFINITIONS

Colleges and Universities Rate Agreement – Federally-negotiated indirect cost agreement negotiated between ¹ú²ú¶ÌÊÓƵand the US Department of Health and Human Services (DHHS).

Facilitates and Administration (F&A) Costs – [see Indirect Costs]

Indirect Cost Rate Agreement – [see Colleges and Universities Rate Agreement]

Indirect Costs â€“Those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved.

Instruction â€“ The teaching and training activities of an institution established by grant, contract, or cooperative agreement. These activities may be offered for credits or on a noncredit basis, and may be offered through regular academic departments or through separate divisions. This term excludes Research Training.

Off-Campus Adjacent – Projects in which all activities are performed in facilities within commuting distance of Tampa, Florida, which are not owned by the institution and where these facility costs are not included in the F&A pools, or where rent is directly allocated/charged to the project.

Off-Campus Remote – Projects in which all activities are performed in facilities outside the commuting distance of Tampa, Florida, which are not owned by the institution and where these facility costs are not included in the F&A pools, or where rent is directly allocated/charged to the project.

On-Campus – Projects in which all activities are performed in facilities which are owned or leased by the institution and where these facility costs are included in the F&A pools; where rent is not directly allocated/charged to the project.

Organized Research â€“ All research and development activities of an institution that are budgeted and accounted for separately. It includes Sponsored Research and University Research.

Other Sponsored Activities â€“ Programs and projects which involve the performance of work other than instruction and organized research such as health service projects, community service programs, service and technical assistance projects, and sponsor-designed testing, clinical trials, evaluations, and non-credit community education.

Research Training – Activities involving the training of individuals in research techniques where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instruction function.

Sponsored Research – All research and development activities that are sponsored by Federal and non-Federal agencies and organizations. This term includes Research Training.

University Research – All research and development activities that are budgeted and accounted for separately by the institution under an internal application of institutional funds. University Research, for purposes of this document, must be combined with Sponsored Research under the function of Organized Research.

CLARIFICATION OR CHANGE

¹ú²ú¶ÌÊÓƵhas negotiated indirect costs for a variety of research categories with our cognizant Federal Agency, the US Department of Health and Human Services (DHHS), which can be found in the Colleges and Universities Rate Agreement attachment on the ¹ú²ú¶ÌÊÓƵFacilitates and Administrative Cost webpage. 

This webpage displays the appropriate rate to be applied for each respective category of research conducted or proposed at USF. The identified indirect cost rate will be applied in all situations except the identified exceptions below.

¹ú²ú¶ÌÊÓƵwill WAIVE indirect costs:

• When required as a condition of a funding opportunity or solicitation.
• When ¹ú²ú¶ÌÊÓƵhas already exceeded a sponsor-required cap or limitation on indirect cost recovery from the sponsoring agency.
• As required by the sponsoring agency for sponsor-funded participant costs. (Refer to CCHIP #012 regarding Accounting for Participant Costs on Sponsored Projects. Indirect costs will be waived on participant costs only—and, only when required by the sponsor. USF’s full negotiated indirect cost rate will apply to all other portions of the award.)
• For student-led research. (If only a portion of a sponsored award supports student-led research, that portion will be accounted for separately in a sub- project for which indirect costs will be waived. USF’s full negotiated indirect cost rate will apply to all other portions of the award.)

¹ú²ú¶ÌÊÓƵwill accept REDUCED indirect costs:

• When required as a condition of a funding opportunity or solicitation. The applied rate shall be the maximum allowable by the sponsor.
• When ¹ú²ú¶ÌÊÓƵwill exceed a sponsor-required cap or limitation on indirect cost recovery from the sponsoring agency. (The appropriate rate shall be the rate that recovers the maximum indirect costs possible within the sponsor required cap or limitation.)

¹ú²ú¶ÌÊÓƵwill NOT waive or reduce indirect costs:

• For Federally-funded programs, per 2 CFR § 200.414(c).
• For Federal funds from a pass-through entity, per 2 CFR § 200.331(a)(4).
• To increase (or perceive to increase) the competitiveness of a proposal.
• To reallocate funding to, or cover a shortfall in, direct-costs categories.
• To cover unexpected costs, or improperly budgeted expenses.
• Because indirect costs were omitted from the proposed or awarded budget.
• To offset a budget reduction.
• Because an award was received in an amount less than expected.
• For the purpose of establishing relationships.
• In anticipation of future funding with higher indirect costs rates.
• To meet required match or cost-sharing requirements.
• When the proposal is not submitted through the approved institutional channel, or does not follow institutional policies, practices, or guidelines.
• For any other reason without the written approval of the Director of Sponsored Research.

PROCEDURES

The application of indirect costs shall be USF’s full indirect cost rate as outlined in the Colleges and Universities Rate Agreement, the ¹ú²ú¶ÌÊÓƵFacilitates and Administrative Cost webpage and this CCHIP unless an exception is outlined explicitly in this document, or approval for a lower rate has been approved by the Director of Sponsored Research. This shall include strict adherence to the definitions of rate types, and research location, including off-campus remote and off-campus adjacent locations.

In the best interest of the ¹ú²ú¶ÌÊÓƵresearch enterprise, exceptions to this CCHIP will be rare. The comprehensive review of any request for waived or reduced indirect costs will include, at a minimum, the following:

• The nature of the research or activity.
• The PI’s justification for the request of waived or reduced indirect costs.
• The sponsoring agency’s allowable indirect cost rate.
• The availability of support from other sources.
• The total proposed budget, and the amount of the requested waiver or reduction.
• The effective indirect cost rate proposed, when considering expense categories exempt from indirect cost under Modified Total Direct Cost (MTDC) requirements.
• The financial impact to the University.
• The financial impact to the College/Department.
• The PI, Department, and/or College’s willingness to be financially responsible for some or all of the unrecovered indirect costs.
• The likelihood of being funded without reducing or waiving indirect costs.
• Precedent that may be established. 

All requests for an exception to this CCHIP shall be submitted to the PI’s assigned Sponsored Research Administrator at least five (5) business days before the proposal due date, and shall include a comprehensive budget, and justification for the request. Requests received less than five (5) business days before the proposal due date will not be considered.

Any proposal submitted outside of the approved institutional channel (Sponsored Research), which does not include full indirect cost recovery, shall be re-budgeted to include full indirect cost recovery prior to acceptance by the University. If re-budgeting is not possible one of the following remedies will apply: (a) the proposal will be withdrawn, (b) the award will not be accepted, (c) an alternate unrestricted funding source(s) will be identified to which the unrecovered indirect costs will be charged. This may include future indirect costs rebates to the respective College, with the approval of the College’s Dean or designee.

CONTACT

Please address your questions regarding this CCHIP to your assigned Sponsored Research Administrator.

RESOURCES

¹ú²ú¶ÌÊÓƵFacilitates and Administrative Cost webpage

EFFECTIVE DATE

This CCHIP is effective as of the date of revision and rescinds all previous versions pertaining to the Assignment of Indirect Costs (F&A) Rates.

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ISSUED: June 1, 2020
LAST REVISION: August 17, 2021