Acceptance of Funds and Facilities and Administrative (F&A) Cost Rates
Acceptance of Funds and Facilities and Administrative (F&A) Cost Rates
I. PURPOSE: To define the conditions for PAVIR to accept or administer funds and to define the F&A (commonly referred to as indirect cost or overhead) rates applicable to differing categories of support.
II. POLICY: It is the policy of PAVIR to administer funds in accordance with VA requirements and in a manner beneficial to VAPAHCS research and education enterprises. Sponsored projects will be administered in accordance with the terms and conditions specified in the grant or contract award and applicable regulatory requirements.
PAVIR does not administer NIH supported T- or K-awards. In addition, PAVIR will not administer awards that are intended for training purposes of early career investigators, especially if those funding opportunities require or are intended for oversight or support by an academic institution.
Differing F&A rates will be applied when funds are accepted, depending on the sponsor’s restrictions or requirements and PAVIR operating policy.
For federal support, we annually negotiate an F&A rate with the Department of Health and Human Services, our cognizant federal agency. The rate in effect as of October 1, 2016 is 38% of modified total direct costs (direct costs less equipment and all but the first $25,000 of subawards). This rate is applicable to all federal and most other governmental support but is subject to limitations prescribed by statute or by agency administrative regulations.
For industry sponsored clinical trials, the standard F&A rate is 30%. This rate is applicable to all such support unless defined differently below.
PAVIR recognizes that some Federal funding instruments include a (low) fixed indirect cost rate, and PAVIR will submit and administer these projects adhering to applicable special conditions.
III. CONDITIONS FOR ACCEPTANCE OF FUNDS:
- All funds accepted by PAVIR must be accompanied or preceded by correspondence in the form of an executed grant, contract, agreement or donor letter.
- Checks must be made payable to the Palo Alto Veterans Institute for Research. The federal tax identification number is 77-0207331. Neither checks payable to other entities nor cash can be accepted by PAVIR.
- Gifts or donations must include a letter from the donor indicating any restrictions on the use of the funding.
- All support accepted by PAVIR represents corporate income and is not to be used for personal benefit of any Principal Investigator, Officer, Director or employee.
- Interest earned accrues to PAVIR Administration and remains with the corporation. All funds accepted for administration by PAVIR must be used for direct or indirect support of research or education. Project, activity or program specific expenditures require Research & Development Committee or Education Committee approval of the associated project, activity or program.
IV. DERIVATION OF SUPPORT AND ASSOCIATED F&A RATES
The principal funding sources and the terms for application of F&A costs to each are:
- Federal Support – Grants or contracts from federal entities should include F&A support in addition to direct costs. The federally established rate for PAVIR is 38% and is applicable unless other arrangements have been approved by the Chief Executive Officer.
- Voluntary Health Agency/Private Foundation Awards – This support is usually derived from nonprofit entities in support of a specific research proposal or career development award. The current federal F&A rate is applicable to this support. If the sponsor limits the amount to be provided in overhead costs and PAVIR elects to accept the award, PAVIR will administer the funds in accordance with the sponsor’s published rate policy. PAVIR understands and supports investigators seeking any kind of funding, and appreciates the need for augmentation of available funding with foundation requests. However, investigators seeking Voluntary Health Agency/Private Foundation Awards should get in touch with the PAVIR Director of Sponsored Research, the PAVIR CFO/COO, or PAVIR CEO as soon as practical.
For proposals with low IDC (less than 15%) PIs must get in touch with the PAVIR Director of Sponsored Research no later than 4 weeks prior to the submission deadline because the PAVIR Board of Directors may decide not to submit a proposal with low (less than 15%) or no indirect costs. The PAVIR CEO, in collaboration with the Director of Sponsored Research will determine which requests for submission must be forwarded for Board determination for submission through PAVIR.
a) How their proposal supports their research
b) How it relates to the VA mission,
c) If, how, and when the resulting data (if funded) will support future research proposals to Federal funding sources.
The Board of Directors will delegate such decisions to one of its officers to avoid undue delays in proposal planning. Decisions will include considerations including:
- Financial impact to the organization for projects with a total budget request in excess of $500,000, or with any of the project year budget requests in excess of $200,000;
- Other available research funding for the proposing Principal Investigator (PI);
- Career stage of the PI;
- Area of research, including whether the proposed research falls into an area of high strategic importance for VA, or if the investigator is exploring a new area of research with the intention of using the project’s data for future Federal applications through PAVIR.
- Collaborative/Therapeutic Research Studies – This support is typically provided by pharmaceutical or other commercial sponsors involved in the development of new drugs, therapies or devices, or for the support of investigator initiated medical research. The non-federal F&A rate of 30% is applicable to this support. It is important that the investigator be aware that such support will be accepted only if there is an agreement or contract executed by the sponsor and signed by the Chief Executive Officer. Acquisition of intellectual property rights will be defined in accordance with federal law and the VA’s CTAA (Cooperative Technology Administration Agreement) with Stanford University. Additionally, if the medical center is providing services required solely by the research activity, there must be approved Clinical Impact Statements or other appropriate documentation for the acquisition of and payment for these services from the PAVIR-administered research support to the VA medical care appropriation. PAVIR investigators considering industry sponsored research are strongly encouraged to contact CRADAs@pavir.org as soon as practical. PAVIR provides significant budgeting, and other project development support at no cost to the PI.
- Gifts, Donations, Education, and Miscellaneous Support – This support is provided from a variety of sources. The F&A rate for this type of support is 30%. This rate may be reduced if all or some of the gift, donation, education or miscellaneous support will be used for infrastructure support. Examples include:
- Support for capital equipment
- IT support
- Support of a clearly defined bid and proposal pilot study
- Non-project specific education support.
Approved by the PAVIR Board of Directors: September 27, 2017