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) 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.
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 a Facilities & Administrative (F&A) rate with the Department of Health and Human Services, our cognizant federal agency. The rate in effect as of October 1, 2014 is 36.1%. It is applicable to all federal and most other governmental support but is subject to limitations prescribed by statute or by federal agency administrative regulations which we acknowledge as acceptable.
For non-federal support, the standard F&A rate is 30%. This rate is applicable to all such support unless defined differently below.
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.
- For gifts or donations there must be a letter from the donor indicating that the funding is a gift to be used by the designated beneficiary in support of various research or education activities. Further, the letter should indicate that the gift is irrevocable and imposes no contractual requirement of PAVIR beyond reporting of research results. Alternatively, if the gift or donation is unrestricted as to use, there must be a letter stating this.
- 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 36.1% 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 non-federal F&A rate of 30% is applicable to this support. If the sponsor limits the amount to be provided in overhead costs, PAVIR will administer the funds in accordance with the sponsor’s published rate policy.
- 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 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 our 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 acquisition and payment for these services from the PAVIR-administered research support to the VA medical care appropriation.
- 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%.