Indirect Costs (F&A) Policy / F&A Waiver-Reduction
Wayne State University's policy is to apply the University's negotiated indirect (Facilities & Administrative, or F&A) cost rate to all externally-sponsored projects. Wayne State Univeristy (WSU) sets indirect (F&A) cost rates with the federal government based on formulas and negotiation processes set forth in the Uniform Guidance.
An explanation of rate and the current Wayne State University negotiated FA rates are available.
Roles and Responsibilities
The fiscal management of sponsored projects, including the application of appropriate indirect (F&A) cost rates in proposed project budgets and management of awarded projects within budget and funding limitations, is the responsibility of the Principal Investigator. The PI is not authorized to negotiate a reduction or waiver of indirect (F&A) costs with the sponsor on any sponsored project. The Principal Investigator shall work with their Research Administrator to submit fully loaded budgets that include both the direct and indirect (F&A) cost of performing research at WSU.
Reductions and Waivers
Indirect Cost (IDC) also known as Facilities & Administrative or F&A rates are not generally waived nor reduced at Wayne State. However, there are exceptions where an IDC reduction or waiver are considered, provided it meets one of the pre-approved exceptions below.
Obtaining an F&A Cost Waiver/Reduction:
A facilities and administrative (F&A) cost waiver/reduction is an institutional agreement that the University will charge F&A costs at a lower rate than the rate reflected in the Colleges and Universities Rate Agreement. Unless a project falls into a limited number of pre-established exceptions (see Section B below), Principal investigators (PIs) must petition for such a waiver/reduction on a case-by-case basis.
Requests to waive or reduce F&A costs in whole or in part require the support of the faculty member, departmental chairperson, and dean. If approved by the vice president of research or his/her designated representative, the agreed upon F&A amount will be divided in the same proportions as if full F&A costs were collected.
All requests should be completed and routed to SPA for review and approval.
Determining if an F&A Cost Waiver or Reduction is Needed:
Review the Colleges and Universities Rate Agreement to determine the applicable full rate for the type of project (research, instruction, other sponsored activity), taking into consideration whether the project will be conducted on or off-campus. Most projects will adhere to these published rates; these projects are considered to be collecting "full F&A".
In addition to these projects, an indirect cost waiver/reduction does not have to be obtained if one or more of the following criteria exists:
- The rate applied to the project is the full applicable rate for the type of project (e.g., industry-funded clinical trial.).
- The governmental or non-profit sponsor has a published rate lower than the full applicable rate. [This does not apply to for-profit agencies, which are expected to pay the applicable full rate.] To be acceptable, the published rate of the non-profit or governmental agency must appear in its guidelines (request for proposal, request for application, broad agency announcement, or other published guidelines) of the agency, or be published on their web site, or be confirmed in writing by their grants office (not a program official.) The lower rate must apply universally to all proposals submitted for that particular program or that agency. The Principal investigator must furnish evidence of the published rate by the time the proposal budget and Cayuse SP proposal is submitted to Sponsored Program Administration for institutional endorsement of the proposal. If such documentation cannot be provided, the Principal Investigator must include the full applicable F&A rate in the proposal.
- If an award is transferred from another institution/entity with direct cost equivalency (the amount of direct costs remaining from the old institution is the same as the direct costs awarded to the University), Sponsored Projects Administration will establish the corresponding award with the full applicable rate outlined in the Colleges and Universities Rate Agreement. The Principal Investigator is held harmless (e.g., the same amount of direct costs remaining upon departure from the old institution/entity will be made available; WSU will cap the F&A amount as needed to ensure direct cost equivalency.) Evidence of the direct cost amounts remaining at the time of the transfer (e.g, via a PHS relinquishing statement, final financial report, or similar documentation endorsed by an institutional official) is required. A note should be added to the Cayuse SP proposal identifying the reduced rate and that it is due to a PI transfer. Note that any additional reduction in rate (beyond maintaining direct cost equivalency) requires an indirect cost waiver.