GAP 200.330, Facilities and Administrative Costs on Sponsored Projects

I. Purpose

Facilities & Administrative Costs (F&A Costs) are costs incurred for common or joint objectives, which cannot be identified with a specific activity, whether sponsored project, instructional or other institutional purpose.

The Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance, includes principles for determining costs applicable to grants, contracts, and other agreements between the Federal government and Duke University. The Uniform Guidance (UG) also defines criteria for determining both direct and F&A costs. For Duke university, the Department of Health and human services (DHHS) reviews and approves the University’s F&A Rates, typically every four years. When completing a proposal for sponsored funding, Principal Investigators (PI) should use the appropriate negotiated F&A Rate on all applications.

This General Accounting Procedure provides a consistent method for evaluating, applying and calculating the F&A charges associated with a sponsored project.

II.  Definitions

Modified Total Direct Costs (MTDC): A subset of the total direct costs associated with a sponsored project, to which F&A applies. Includes direct salaries and wages, applicable fringe benefits, supplies, materials, services, travel and up to the first $25,000 of subawards. It does not include capital expenditures including equipment, charges for patient care, tuition remission, off-site facilities rental costs, participant support costs, scholarships and fellowships, and any portion of subawards >$25,000.

On-/Off-campus designation: Determined at the time of proposal, a project is off-campus if >50% of the project is performed off-campus. In general, on-campus buildings are those buildings owned or leased by the University as an institution. If there is uncertainty about whether a project is off-campus, contact the appropriate pre-award office.

Rate Agreement: A document, signed by University and Federal officials, that provides the negotiated F&A Rates for sponsored projects. These agreements include rates for organized research (on and off campus), instruction, and other sponsored activities. For descriptions and applicability of negotiated F&A rates, see section III, F&A Rate Types.

Unallowable Costs: Specific activities or transactions, as listed in the UG, that are not allowed to be charged to sponsored projects, either as a direct or F&A Cost (Further information provided in GAP 200.340, Cost Accounting Standards). These can only be charged with the explicit approval from the sponsor. Individual agency and program requirements may list other unallowable costs; consult the Notice of Award and Terms & Conditions for specific guidance.

III.  F&A Rate Types

1. Organized Research: Includes research and development activities that are separately budgeted and accounted for, and have definite objectives.  Clinical trials are considered research. These projects are located in the restricted xx3 WBSE series.

2. Instruction: Includes those activities offered through regular academic departments or other units, such as summer school, whether they are offered for credit towards a degree or on a non-credit basis. This also includes instruction, course and curriculum development, academic advising and scholarly activities such as preparing papers, delivering papers, attending seminars and professional society meetings. These projects are located in the restricted xx1 and xx2 WBSE series.

3. Other Sponsored Activities: Includes those funds that involve performance of work not described in the preceding categories. These projects are located in the restricted xx9 WBSE series. Some examples include:

   • Awards supporting travel, conferences, symposia, workshops, and seminars that do not otherwise meet the criteria for research or instruction;
   • Public Service, inclusive of health service, legal clinics, sustainability, and curriculum development;
   • Public events – sponsorship of museums, arts, dance, film, and music programs;
   • Duke University Press publications.

IV. Procedure

1. Determine appropriate rate type and base for a sponsored research project. When developing a project proposal, the PI should consider the location and type of project, and review sponsor guidelines to identify the appropriate F&A rate to be included in the proposal. 

   If the F&A Rate used in the proposal is anticipated to be anything other than the appropriate negotiated rate, departments must seek approval from the appropriate University office. The Office of Research & Innovation (OR&I) manages requests and approvals for those departments in the Provost’s Area Management Center (PAMC). Department representatives should contact their Office of Research Support liaison during budget development to initiate the process. For those departments in the School of Medicine (SOM), requests are submitted using the F&A Waiver form and managed by the School of Medicine Dean's Office. For the School of Nursing (SON), department representatives should contact the Vice Dean, Finance and Administration for review and management of requests. Management Centers should adhere to the principles identified in the F&A Costs: Reduced and Waived Rates when considering request for rates other than the appropriate negotiated rate.

2. Calculating project budgets using F&A. Once the applicable rate is identified or another rate is approved, the PI should apply that rate to MTDC in all budget calculations and projections.

3. Charging F&A. As a part of fiscal period close, Post-Award Financial Management calculates the F&A charge and allocates the appropriate amount to each sponsored project. To ensure accuracy, all project costs should be charged to the proper G/L accounts throughout the life of the project.

V. F&A Rates for Subrecipients

The management of subawards should adhere to the standards outlined in 2 CFR 200.330-200.331 and GAP 200.280, Subrecipient Management. Under these procedures, the departments have responsibility for reviewing the terms and conditions of the subaward, which includes review of the appropriate F&A rate application. In 2CFR 200.331 (a)(4), the UG states that a subrecipient may identify one of the follow F&A rate applications:

1. An approved, federally-recognized F&A rate, as negotiated between the subrecipient and the Federal government.
2. If no such rate exists, the subrecipient may elect to charge a de minimis F&A rate, which is currently 10% of MTDC.
3. In rare instances, the subrecipient may request to negotiate an F&A rate directly with Duke. If the subrecipient wishes to pursue a negotiated rate, the PI must refer the request to the Office of Research Support or the Office of Research Administration. The Office of Cost Reimbursement and Analysis is responsible for reviewing the materials and negotiating a rate in compliance with the UG.  If a negotiated rate cannot be reached, the de minimis rate will apply.  The subrecipient must provide:
   1. Most recent fiscal year-end financial statements reviewed by an independent public accounting firm and,
   2. Most recent fiscal year-end trial balance that ties to the financial statements and,
   3. F&A cost rate proposal, including calculated and required F&A cost rate.

If the Federal sponsor has a published cap on F&A recovery, the lower rate must be applied. PIs should consult award documents to ensure they are complying with all sponsor requirements.

VI. Federal Regulations

This GAP reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance. The UG became effective as of December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor’s policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc.

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.