Q: What is the F&A Cost Rate?
A: The F&A (facilities and administrative) rate is a method that the federal government has implemented to help reimburse many types of routine, but at times unrecognized, costs that support a project. These costs are difficult to assign with a degree of precision as are the more obvious "direct" costs, or without significant accounting processes (and additional costs) to administer. Electricity, for example, to support research in the lab, would be unfeasible to attempt to charge as a direct cost to each project that may be undertaken in the lab. Access to the building, furnishings, and general equipment all provide support to various projects, yet being able to distribute those costs as a direct cost again is unfeasible. The F&A rate is, thus far, the most practical method of allocating a variety of costs to a sponsored project. Overhead costs are real operational costs from accounting records of the university, and they must be allocated to the benefiting functions and then assigned to the various departmental project accounts. If these costs are not reimbursed by the sponsor, they will be absorbed by the student (higher tuition fees), the state (higher taxes), or the institution (e.g., the transfer of funds from instructional programs to administrative support). Reference: F&A Information.
Q: What is the current F&A Cost Rate?
A: The F&A (facilities and administrative) rate is based on an agreement with Clemson University's cognizant federal agency, the Department of Health and Human Services. The current F&A Rate Agreement, available via the link below, is valid through June 30, 2015. Projects that were awarded previous to the establishment of the current rate will continue at the old rate unless additional funds are requested for that grant or cooperative agreement.Reference: F&A Information.
Q: What is the fringe benefits (FB) rate?
A: Clemson University currently has a Pooled Fringe Benefit Rate Agreement. The current Pooled Fringe can be found at http://www.clemson.edu/cfo/comptroller/rates/index.html.
Q: How do I determine which classification to select in the section of the Proposal Processing Form (OSP-1) entitled “Classification?”
A: Classification is determined based on the primary purpose or major objective of the activity the funds will sponsor. To determine the appropriate category for your proposal, see Classification of a Proposal.
Q: What action is required if “Yes” is answered to human subject, animal subject, or hazardous materials involvement on the Proposal Processing form?
A: Contact the Office of Research Compliance to begin the protocol submission process.
Q: What is Clemson University’s Tax ID number?
Q: What is Clemson University’s DUNS number?
Q: Can I pay another Clemson University faculty member as a consultant?
A: Consulting fees can only be paid to faculty of the same institution under unusual circumstances: a) the work performed by the faculty member is in addition to his or her regular department load and other arrangements are not possible, and, b) if the consultation is across departmental lines, or involves a separate or remote operation. Prior approval from the College Dean of each proposed faculty consultant is required.
Q: Why does the Office of Sponsored Programs require that the entire proposal be submitted?
A: The Office of Sponsored Programs reviews various information on the proposal such as, but not limited to, research compliance issues, whether costs are allowable, allocable, and reasonable; if cost sharing is required, if F&A requirements of the sponsor are being met; as well as verifying that sponsor requirements and University guidelines and objectives are being met. Information concerning sponsor type, funding source, and other variables are entered and tracked by the Office of Sponsored Programs and the Division of Research for reporting purposes.
Q: Is Participant Support Costs excluded from F&A cost calculations?
A: When preparing proposal budget/financial plans, several budget categories are excluded when arriving at the base amount to which the appropriate F&A rate is applied (see definition from NSF Grant Proposal Guide below).
(v) Participant Support (Line F on the Proposal Budget):
This budget category refers to costs of transportation, per diem, stipends and other related costs for participants or trainees (but not employees) in connection with NSF-sponsored conferences, meetings, symposia, training activities and workshops." (See GPG chapter II.D.7). For some educational projects conducted at local school districts, however, the participants being trained are employees. In such cases,
the costs must be classified as participant support if payment is made through a stipend or training allowance method. The school district must have an accounting mechanism in place (i.e., sub-account code) to differentiate between regular salary and stipend payments. Generally, indirect costs (F&A) are not allowed on participant support costs. The number of participants to be supported must be entered in the parentheses on the proposal budget. These costs also must be justified in the budget justification section of the proposal. Some programs, such as Research Experiences for Undergraduates, have special instructions for treatment of participant support.
In the absence of a sponsor specific restriction, the budget category of participant support should not be excluded from the F&A base. The exclusion of participant support is a National Science Foundation specific policy. If uncertain, review announcement guidelines to determine applicability.
Q: What is MTDC?
A: Modified Total Direct Cost (MTDC) is determined by subtracting the cost of equipment, tuition, fellowships, and subcontract amounts over $25,000 from the total direct costs to determine the F&A base, to which the applicable rate is applied.
Q: Is it permissible for the department chair's secretary or others to sign the Proposal Processing form for the principal investigator?
A: No, the principal investigator and other investigators must personally sign the Proposal Processing form.
Q: Is it permissible for others to sign for the authorized representative of the Department or College on the Proposal Processing form?
A: No, only those individuals authorized by the Associate Research Dean of each College may sign on behalf of the College. The signature certifies personal awareness of the proposal and issues pertaining to intellectual property and financial disclosure policies of the University. Reference: College Contacts and Proposal Review Responsibilities (pdf).
Q: Why is a signature required if the sponsor doesn't require a signature on the sponsor proposal application form?
A: University policy states that all proposals for funding must be signed by the Interim Vice President for Research, Dr. Larry Dooley, or his authorized representative, certifying that: a) it meets the University’s mission(s) objectives and stated sponsor’s solicitation requirements; b) awards will be performed within constraints of the grant or contract terms and conditions; and, c) the University will maintain, or implement if necessary, operational policies and procedural standards that comply with appropriate federal policies or regulations. Reference: Memo to the Vice Presidents, Deans and Academic Directors, Signature Authority and Name of Legal Applicant for Sponsored Program Funding, dated Feb. 4, 2002. Reference: Signature Authority Policy.
Q: Why is a Proposal Processing form and signature required for an electronic proposal submission?
A: Clemson University requires that all proposals be routed through the Office of Sponsored Programs in order to: a) verify that the proposal meets the University’s objectives and the sponsor’s requirements; b) assure that awards will be carried out according to grant or contract terms and conditions; and, c) assure that the University maintains and/or implements operational policies and procedures to comply with federal policies and regulations. The Proposal Processing form provides the Office of Sponsored Programs with the necessary information to track grant and contract funding for the University.
Q: Who is authorized to sign grants and contracts on behalf of Clemson University?
A: The Interim Vice President for Research, Dr. Larry Dooley, or his designee in the Office of Sponsored Programs. Reference: Memo to the Vice Presidents, Deans and Academic Directors, Signature Authority and Name of Legal Applicant for Sponsored Program Funding, dated Feb. 4, 2002. Reference: Signature Authority Policy.
Q: Is it permissible for the principal investigator, department chair or dean to sign the contract agreement?
A: No, the Board of Trustees has delegated that authority to the Vice President for Research; therefore, contracts must be signed by the Vice President for Research, or his designee.
Q: Should the Clemson University Proposal Processing form (OSP-1) be submitted to the sponsor?
A: No, the form is for internal purposes only.
Q: How much time is needed by the Office of Sponsored Programs to process a proposal?
A: At least three (3) business days are needed to process a proposal to allow for appropriate review and to obtain corrections, if needed. Routing time for obtaining appropriate signatures at the department and college level must be considered prior to proposal arrival at the Office of Sponsored Programs.
Q: When are funds considered to be a small restricted receipt?
A: Funds less than $15,000 given to a principal investigator for a restricted or unrestricted purpose that are not subject in any manner to a service contract or grant as a condition of receipt are considered small restricted receipts. All other funds are considered grants, cooperative agreements, or contracts and are subject to all applicable laws and rules.
Q: How is a gift that can be applied to research processed?
A: Submit the check and all relative documentation to the development office.
Q: What is the electronic award notice e-mail address for Clemson University’s Office of Sponsored Programs?
Q: What is a cooperative agreement? How is this different from a grant? Does it make any difference in the budget?
A: Normally, the University receives three types of funding agreements: contracts, grants and cooperative agreements. Federal agencies determine the particular type of agreement to be issued under federal guidelines based on whether the federal agency is approaching it as a “Procurement” or a “Financial Assistance” action. There is no impact on the budget process regardless of agreement type.
Procurement Action — The two considerations for a contract to be issued is that the sponsor has determined:
This type of action is one under which the federal government is actually buying (hence “procurement”) goods or services from a contractor/vendor. The process normally revolves around a federal agency’s issuance of a Request for Proposal (RFP) which specifically details what they expect to receive (i.e., “deliverables”) and the various terms and conditions which must be met by the selected bidder. The selected bidder will be issued a contract document by the sponsor that legally binds the two parties to the final set of terms and conditions. The contractor must then abide by this document in providing the particular service (e.g., specifically described research performance) and/or the product or materials being “procured.” For research contracts, the deliverables are not only the actual performance of the research itself, but also any items listed in the “Deliverables Section” of the contract (e.g., the various technical reports and formal or informal communications to the sponsor).
Financial Assistance Action — In this type of action, the federal agency has determined that:
The principal purpose is to transfer a thing of value (e.g., funding) to a recipient, who in turn agrees to carry out a public purpose assigned (by U.S. Congress) to the funding agency. The mechanism under which this “transfer of value” takes place is either a “grant” or a “cooperative” agreement. By definition, the stated difference between the two rests on the degree of participation needed from the sponsoring agency. If substantial involvement is expected from the sponsor, then a cooperative agreement will be issued; otherwise, a grant agreement will be issued and the recipient (grantee) assumes fuller control of, and responsibility for, achieving the project’s objective.
Q: Can we negotiate and budget a "per inspection" fee with a sponsor to cover employee time, travel & other miscellaneous expenses? What is the best way to do this?
A: To negotiate and budget a “per inspection” fee would probably require the establishment of a billing rate. You would need to contact the office of the comptroller concerning this. Otherwise, all costs would need to be budgeted separately as salaries, fringe, travel, supplies, etc.
Q: How do you calculate course buy-out for grants? When is it okay for a faculty member to buy-out time for research? How do you calculate faculty release time? When can it be counted as cost sharing? What determines when faculty release time can and cannot be included in the grant or cost sharing?
A: Under the requirements of OMB Circular A-21, faculty salaries must be calculated and expressed as a percent of effort. In line with approved policy of the Academic Council (Feb. 2, 1999), faculty may be released from a three-hour teaching course per semester if 25 percent of that semester’s salary is charged to (or cost-shared on) an externally funded project.
Refer to the sponsor’s announcement or guidelines to determine requirements regarding cost sharing. Unless cost sharing is required by the sponsor’s announcement, most federal agencies do not expect the University to volunteer cost sharing of faculty release time, or other items of cost for cost sharing. The Clemson University cost share agreement must be completed when cost sharing is budgeted.
Q: Can general office supplies, i.e. telephone, paper, toner, clerical assistance, etc., be included as “supplies” on grants? It has always been my understanding that these costs are the price of doing business and should come from the indirect cost. Which is correct?
A: Office supplies (pens, paper, notebooks, clips, stamps, envelopes, ink cartridges/copying toner, local telephone service, etc.) are those costs that are incurred for a “common or joint objective” of the university and, therefore, cannot be identified readily and specifically with a particular sponsored project. While one can easily recognize that a notepad might be “needed” for a research project, we don’t want to have to set up an accounting system to track all of the department’s notepad inventory in order to direct cost them to all the various accounts/projects on which they are used. So, although it is possible to practically direct charge any cost to a project, the accounting system that would be required and the staff effort to ensure each unit of these various costs are properly distributed makes it an unrealistic and inefficient way of handling such costs.
Therefore the federal cost principles expect the University to normally absorb these charges by unrestricted operational accounts and recover those costs through the indirect cost reimbursement process. This expectation holds true even where in some cases the federal sponsor imposes F&A rate restrictions on certain grant programs.
Clerical staff, i.e., those individuals that provide general support to departmental functions and whose time associated with each of the many individual tasks would be difficult, impractical and/or inefficient to track to each of those benefiting “tasks,” are assigned under the category of “departmental administration.”
The F&A recovery process generates several millions of revenue dollars for the University as the sponsored projects are invoiced. It is these revenues that “replenish” the departmental E&G or PSA (State) funded accounts from which the departmental supplies, services, and clerical support were charged. From this perspective, it should not be difficult to understand why the Federal cost principles expect the University to be reimbursed by the F&A cost recovery process, and not by direct charging these costs to a project.
There are exceptions to the rule. A major project requiring a full time clerical employee could possibly be an extraordinary circumstance, thus justifying the direct costing of clerical salaries. Other examples, as provided from OMB A-21 Circular’s Exhibit C are provided below.
These examples are not exhaustive nor are they intended to imply that direct charging of administrative or clerical salaries would always be appropriate for the situations illustrated in the examples. For instance, the examples would be appropriate when the costs of such activities are incurred in unlike circumstances, i.e., the actual activities charged directly are not the same as the actual activities normally included in the institution's facilities and administrative (F&A) cost pools or, if the same, the indirect activity costs are immaterial in amount. It would be inappropriate to charge the cost of such activities directly to specific sponsored agreements if, in similar circumstances, the costs of performing the same type of activity for other sponsored agreements were included as allocable costs in the institution's F&A cost pools. Application of negotiated predetermined F&A cost rates may also be inappropriate if such activity costs charged directly were not provided for in the allocation base that was used to determine the predetermined F&A cost rates.
Q: What items should be included in the “equipment” section of the budget?
A: The University defines “equipment” as any tangible, nonexpendable property having: (1) a useful life of more than one year, and, (2) an acquisition cost of $5,000 or more per unit. Items not meeting these two conditions are not to be classified as, and placed in, the equipment category.
Q: Subcontract documentation and/or documentation of consultants to be hired is often not in place at the time when the proposal is due. Can this type of documentation be turned in after the proposal is submitted to OSP?
A: A quoted price for services from a consultant, collaborating institution, or other organization must be “backed-up” in writing from that party. This documentation (e.g., a proposal which contains the proposed technical work, a budget estimate, and authorized institution/company signature) is required as a matter of sound business practice to indicate that Clemson University has reviewed and accepted that party’s intended participation, and therefore supports inclusion of that activity as part of CU’s proposed effort.
Additionally, by inclusion of this material in the University’s proposal, OSP is therefore authorizing the issuance of the appropriate agreement to the named party without the requirement of competitive bidding processes and the associated delay of getting that work started. When the party is named and their Scope of Work (SOW) is sufficiently described as a part of the University’s application, a Procurement Certification can then be used by OSP to proceed with issuance of the sub-agreement upon award.
We recognize that in some situations, PI’s may not have been able to determine the specific party needed. In this case, utilization of an open bid process is probably the only method available to meet federal and/or SC State procurement practices. The objective of such bid procedure is to provide reasonable opportunity for a competitive selection of the most qualified “service provider” based upon the selection criteria established by the PI.
Q: If something is listed as not being “allowable” as grant costs, but it has been specifically listed in the work/budget plan that is submitted and approved by the sponsor, can it be purchased anyway?
A: Keep in mind that in many cases, as a result of the imposition of the Cost Accounting Standards (CAS), federal sponsors no longer perform in-depth reviews of proposal budgets. Under CAS, the federal agencies expect the applicant to be familiar with the A-21 Cost Principles and to exclude non-allowed costs from those budgets. As a result, Universities cannot depend on the “rationalization” that since the sponsor did not remove it from the awarded budget that, in fact, the sponsor has “approved” that cost item. In order to position your argument along that line, at a minimum the proposal’s budget should include a separate page titled “Budget Justification” in which those non-routine or normally non-allowed expenses are identified and justified for the project – OSP initially must make the judgment call based upon the circumstances of the PI’s justification.
Q: How do I calculate the F&A on subcontracts?
A: F&A costs are calculated on the first $25,000 of each subcontract.
Q: Is an itemized budget required by OSP on NIH programs that only need a modular budget?
A: Although NIH has adopted the modular budget format for budgets of $250,000 per year and less, Clemson University, as do many universities, requires a detailed itemized budget for internal purposes. Under Cost Accounting Standards (CAS), the burden is on the University to apply costs consistently. Without a detailed budget, OSP does not have any way to assure costs are in general compliance with CAS. An Internal Budget form is now included as the last page of the Proposal Processing Form.
Q: Where can I find a really good detailed explanation of cost sharing? Is the requirement for cost sharing and the amount required always established by the sponsor?
A: There are two terms, “matching” and “cost sharing,” that are often used interchangeably. “Cost Sharing/matching” is used when the sponsor has specified a particular dollar to dollar (or ratio) requirement which is to be supplied from non-federal sources in order to receive the federal (or sponsor) funding, i.e., the sponsor has essentially established what the applicant will share. “Cost sharing/matching” therefore refers to any portion of the project’s costs not borne by the sponsor. For Clemson University’s purposes, all cost sharing is accomplished either as a cash outlay (an expenditure) or as waived F&A costs. Existing University resources (space, equipment, supplies on hand, etc.) are not allowable as cost sharing.
Tips to determine allowability for federal cost sharing or matching:
All of the above conditions must be met in order for a cost item to be claimed or proposed as cost sharing or matching. The concept of “in-kind” cost sharing means that the University is to receive from an entity or individual - other than the sponsoring agency or the University’s own sources — items such as services and supplies through a process under which no cash transaction takes place.
Q: Can the University and federal guidelines, policies, and regulations be put into a "non-technical” document for ease of understanding and to make it easier to explain to PIs?
A: As far as OSP policy and procedures are concerned, efforts are customarily made to translate, interpret and communicate sponsor (primarily federal) policy and procedures in as “non-technical” terms as possible.
The difficulty lies in providing total coverage of all federal and other sponsor requirements. The tremendous quantity of federal policy and procedures throughout the sponsored program environment makes total coverage impractical. In order to translate “federal-ease” into non-technical terms, it often requires significantly more written space than the original federal statement; consequently, one then faces the problem of providing such a quantity of information that few have the desire to read it in order to be knowledgeable enough to follow it.
OSP highly recommends a well-written manual entitled A Guide to Managing Federal Grants for Colleges and Universities, co-produced by the National Association of College & University Business Officers (NACUBO) and the National Council of University Research Administrators (NCURA). This manual translates the essential elements of federal grant/cooperative agreement policies (primarily stemming from OMB Circular A-110) into non-technical terms. Subscription to the manual may be ordered by calling (800) 521-4323 (Customer Service). Monthly updates to federal policies are provided, as well as a newsletter that overviews upcoming or recent federal policy issues and some federal grant opportunity announcements.