F&A Guidance on Federal Awards

Please view this short video for an overview of Facilities & Administrative Costs at Universities 

Brown University Current Rate Agreement

Guidance on Reconciling Facilities & Administrative Costs can be found here.

Please see the rate table below for current and future rates approved under this agreement:

*Awards funded on or after July 1, 2022 are subject to this new rate agreement.

**Awards which were funded before July 1, 2022 are subject to the University’s previous rate agreement dated 3/18/22.

Examples

Scenario 1  - Award Funded in FY21
An NIH on-campus research award started on June 1, 2021 and utilized a rate of 58.5% for the first month of the project and then changed to 59% on July 1, 2021.  The rate changed again on July 1, 2022 to 59.5%.  All future years of this award through June 30, 2027 will continue to use the 59.5% rate.  After June 30, 2027, the 59.5% rate is provisional, until a new rate agreement is adopted.  Supplements to this award will use the rate agreement in effect at the time of the NOA. 

Scenario 2 – Award Funded in FY22
An NSF on-campus research award started on August 1, 2021 with a rate of 59% for the first 11 months of the project before changing to 59.5% on July 1, 2022.   All future years of this award through June 30, 2027 will continue to use the 59.5% rate.  After June 30, 2027, the 59.5% rate is provisional, until a new rate agreement is adopted.  Supplements to this award will use the rate agreement in effect at the time of the NOA.

Scenario 3 – Funded in FY23
An NSF on-campus research award with a start date of August 1, 2023 will have the rate of 59.5% through 6/30/27 and thereafter, until the provisional rate of 59.5% is amended after July 1, 2027.    

Frequently Asked Questions

Definitions

How does a provisional rate differ from a predetermined rate?
A Provisional rate is a temporary indirect cost rate applicable to a specified period which is used for funding, interim reimbursement, and reporting indirect costs on Federal awards pending the establishment of a final rate for the period. 

A Predetermined rate is applicable to a specified current or future period, usually the organization's fiscal year. The rate is based on an estimate of the costs to be incurred during the period. A predetermined rate is not subject to adjustment.

Pending Proposals & Existing Awards 

How are previously submitted Proposals affected by this rate change?
The new rates will be used for all awards made on or after July 1, 2022, regardless of what rate was used in the proposal budget. There will be no change in the F&A rate for proposals submitted using a provisional rate from the prior rate agreement.  The predetermined rates for 7/1/2022 – 6/30/2027 are the same as the provisional rates in the previous rate agreement.   

How will the F&A rate be applied to existing Federal multiyear grants and contracts?
Review the rate agreements in effect during the grant/contract years for the predetermined rates per grant year.  Rates changed annual between 07/01/2019 – 06/30/2023.  From 07/01/2022 – 06/30/2027 the predetermined on-campus research rate is 59.5%.    

Which rate should be used for Competitive Renewals?
All requests for new funding, including NIH* Supplements and Competing Renewals should use the new rate structure regardless of when the original award was funded.

Should Supplement Requests use the same rate as the Parent Award?  
Not necessarily. The current rate agreement applies to all new funding, which can include Supplements. Unless the sponsor policies state otherwise*, Supplement proposals should incorporate the new rates, even if the Parent award was funded before July 1, 2022.

*NSF has a policy of funding supplemental support using the negotiated indirect cost rate(s) approved at the time of the initial award, so supplemental proposals to NSF should use the original agreement's rates. See NSF PAPPG Chapter VI.E. Note that most NSF supplements submitted by Brown are for REU/Participant Support, which generally don’t include F&A. 

What F&A rate is applied to Carryover funding?
Carryover is subject to the F&A rate in effect when the costs are incurred.

How will the F&A rate be applied to existing Non-Federal projects?
If the Non-Federal Sponsor has a published rate which is lower than Brown’s negotiated rate, that lower rate can be used for proposals submission as long as documentation of the rate restriction is uploaded to the proposal record.

If the sponsor does not have a rate limitation and Brown is able to recover our full F&A, the same principles outlined above will apply. Awards funded on/after July 1, 2022 are subject to this new rate agreement. 

If we are a subrecipient on an existing award and the sponsor institution requests an updated budget each year, should we use the new F&A rates when preparing our budget?Assuming that the sponsor issues modifications extending the subaward each year, the rate agreement in effect at the time the subaward was originally issued remains effective throughout the life of the sub.  So if the subaward began before July 1, 2019, the rate of 62.5% is maintained throughout.  If the sub was issued on or after that date, it falls under the new rate agreement and should use the new rate structure.  If the sponsoring institution is issuing a new, separate subaward, the new rates would be used.

To submit new a FAQ, please contact [email protected]