VCU Guidelines for Facilities and Administrative Cost Recovery

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.

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 facilities and administrative costs except in accordance with the procedures described in these guidelines.

Exemptions do not apply to for-profit sponsors.

Exemptions for government and non-profit sponsors

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

  1. F&A costs may be reduced or waived when expressly limited or forbidden by federal law or administrative regulation, state law or administrative regulation, or the published policy of a governmental or non-profit sponsor.
  2. F&A costs may be reduced or waived for government or non-profit sponsors when the Vice President for Research and Innovation judges the project to be of exceptional academic merit.
  3. F&A costs may be reduced or waived when the Vice President for Research and Innovation 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

  1. Each proposal forwarded to OSP for review which includes less than the full appropriate F&A under Exemption #1 above should include a copy of the law, regulation or published policy of the sponsor.
  2. Each proposal which includes less than the full appropriate F&A not exempt under No. 1 above must be accompanied by a letter from the Principal Investigator/Project Director’s department chairperson, concurred with by the appropriate dean. This letter should state the amount of cost being subsidized, cite one of the exemptions listed above, and justify persuasively to the Vice President for Research and Innovation 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.

Approval/Review Process

The Vice President for Research and Innovation delegates to the Assistant Vice President for Research Administration, the authority to grant appropriately documented requests for reduction or waived for F&A costs at the latter’s discretion.