Facilities and Administrative Cost Recovery Guidelines

Full Recovery Principle

As specified in the Appropriations Act, VCU will apply the full federally negotiated F&A cost rate(s) to proposals and agreements for all grants, contracts or other agreements proposed and/or accepted, including those with other agencies and instrumentalities of the Commonwealth, unless exempted as described below:

Exemption:

1. F&A costs may be reduced or waived when expressly limited or forbidden by federal laws or administrative regulation, state law or administrative regulation, or the published policy of a governmental or non-profit sponsor.

Extraordinary or unusual circumstances may lead VCU to apply one of the exemptions listed below if the Vice President for Research deems the proposed/agreed activity to have significant benefit to the University based on written justification from PI’s Chair and Dean:

2. F&A costs may be reduced or waived when the Vice President for Research judges the project to be of exceptional academic merit.

3. F&A costs may be reduced or waived when the Vice President for Research deems F&A one of the costs for VCU to contribute to meet mandatory cost sharing. Mandatory cost sharing occurs when the published policy of a governmental or non-profit sponsor requires that the recipient must share in the total cost of the project and provide the sponsor records of that cost sharing.

Procedures for Obtaining and Documenting Each Exemption (in accordance with Exemption number listed above):

Exemption:

1. Provide a copy of the law, regulation, or published policy limiting F&A recovery at the time of proposal submission to OSP.

2. Provide a request letter from the Principal Investigator’s Department Chair and Dean stating the unrecovered F&A amount and persuasively justify the benefits the University will derive from proposing and accepting the project at a reduced cost. Requests will not be considered unless both levels of academic management have approved. The request, with approving signatures, shall be retained in the proposal/project file as documentation of the approved exemption.

3. Provide a request letter from the Principal Investigator’s Department Chair and Dean stating the amount of F&A to be cost-shared and persuasively justify the benefits the University will derive from proposing and accepting the project at a reduced cost. Requests will not be considered unless both levels of academic management have approved. The request, with approving signatures, shall be retained in the proposal/project file as documentation of the approved exemption.

Limitation of total project costs by the sponsor is not justification for less than full F&A recovery.  Projects should be scoped and costed to meet the sponsor cost limitation.

Project costs shall not be quoted to potential sponsors with less than full F&A costs except in accordance with the procedures above. The fact that such a quotation has been erroneously given is not justification for a reduced F&A cost rate.