Office of Research & Creative Scholarship

Category: Federal Regulations

New Facilities and Administrative (F&A) Costs Rates for Grants Effective July 1, 2023

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On June 23, 2023

In Director's Message, Federal Regulations, Policies, Procedures

Dear Emerson community members:

Every few years, Emerson College is required to negotiate the Facilities and Administrative (F&A) rates it uses in grants and contracts with the Federal Government. This month, Emerson received our new Rate Agreement from the Department of Health and Human Services for the period of July 1, 2023 through June 30, 2027, or until amended.

Effective immediately, the revised rates must be used for all federal sponsored project proposals with anticipated start dates of July 1, 2023 or later.

The new rates are as follows:

Indirect Costs/Overhead

FromToRateLocationApplicable To
07/01/202306/30/202756%On campusAll programs
07/01/202306/30/202726%Off campusAll programs
07/01/2027Until amended56%On campusAll programs
07/01/2027Until amended26%Off campusAll programs

Fringe Benefit Rates

FromToRateApplicable To
07/01/202306/30/202732%Full-time employees
07/01/202306/30/20277.65%Part-time employees
07/01/2027Until amended32%Full-time employees
07/01/2027Until amended7.65%Part-time employees

These rates will apply to all new or new-continuing contracts and grants awarded for funding on or after July 1, 2023. Existing contracts/grants may still use the old rates as originally awarded.

As a reminder, it is the policy of Emerson College to request indirect costs on proposals to non-federal sponsors, when permitted. Many foundations specify their own indirect cost rates, and it is the policy of the College to utilize these rates in its proposal budgets. When a non-federal sponsor is silent on F&A, a de minimis rate of 10% should be applied.

To learn more about F&A costs and how they are budgeted and recovered, please review the answers to Frequently Asked Questions (FAQs) below. 

FAQs

What are Facilities and Administrative Costs? 
Also referred to as indirect costs, F&A costs are expenses incurred by an organization that cannot be identified readily and specifically with a particular sponsored project but contribute to the ability of the College to conduct sponsored projects.  Expenses of maintaining and operating the College’s sponsored project infrastructure include costs related to buildings (labs, offices, training facilities, etc.), utilities (water, electricity, heating, air conditioning, etc.), maintenance (custodial and facilities services, etc.), equipment, libraries, general administration (purchasing, accounting, payroll, human resources, legal services, etc.), departmental administration (deans offices, academic departments, etc.), and sponsored project administration.  These costs are considered F&A costs, and sponsoring agencies reimburse organizations for these expenses through an F&A rate. 

To what budget items does the F&A rate apply?
All rates are applied to a Modified Total Direct Costs (MTDC) base.  The MTDC base includes all direct costs, excluding capital expenditures, equipment with a per-unit cost of $5,000 or more, charges for tuition remission, rental costs of off-campus facilities, scholarships, fellowships, participant support costs, and the portion of each subaward

Why does the College require project directors to budget for F&A costs?
F&A costs are actual costs that are incurred by the College in administering a sponsored award.  Because it is not practical for a project budget to allocate funding for all such costs, the Federal government utilizes a rate model to account for these expenses and to provide a fair and consistent method through which reimbursement can be made. The College requires that sponsored project budgets include F&A costs because facilities and administrative expenses are incurred for each sponsored project, and without funds to cover these costs, the College would not have an infrastructure that could support sponsored projects.  It would be unfair to require students to cover these costs through tuition revenue, especially for projects that are not for their direct benefit.

How are the rates determined?
The Federal government outlines specific procedures to be used in determining the rates and requires institutions to provide a proposal and financial data in accordance with these procedures. The government then uses a detailed review process to arrive at approved rates for each organization. The rates are not set by the College and cannot be amended without a new Federal rate agreement. 

What does the College do with funds recovered through the F&A rate?
Recovered F&A funds are used to help offset the College’s facilities and administrative expenses.

What if I want to apply to a funding program that limits or prohibits F&A costs?
If a sponsoring agency limits or prohibits the recovery of F&A costs, the College currently accepts these restrictions and subsidizes the F&A costs provided that written documentation (i.e., policy statement or application guidelines) from the sponsoring agency is provided when the proposal is submitted for internal review.

What if I have a current sponsored project award that uses a lower rate?
The revised rates apply only to new awards and do not impact existing awards. Effective immediately, project directors are required to use the new rates for all proposals submitted for internal review.

If you have questions about budgeting for F&A costs, please contact the Executive Director for the Office of Research and Creative Scholarship with any questions.

NSF Update: Required Use of Research.gov for Proposal Submissions

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On March 22, 2022

In Federal Agency Announcements, Federal Funding, Federal Regulations, Procedures

In accordance with Important Notice No. 147, many National Science Foundation (NSF) program solicitations now require the use of Research.gov for the preparation and submission of proposals. Please be advised that NSF will now start requiring the use of Research.gov for the preparation and submission of proposals in response to program descriptions. As a reminder, FastLane is targeted to be removed as a submission option from all funding opportunities when the Proposal and Award Policies and Procedures Guide (PAPPG) goes into effect in January 2023. Grants.gov will remain a submission option for most NSF proposals.

National Science Foundation on Twitter: "Beginning on April 30, proposers can prepare and submit full, research non-collaborative proposals in https://t.co/gYl000AH6f or in FastLane. Check out the new https://t.co/gYl000AH6f proposal site features ...

Program Descriptions in Research.gov
To assist the research community, NSF developed a dynamic listing of program descriptions that require submission in Research.gov. Follow these steps to determine if your proposal for a specific program description must be prepared and submitted in Research.gov

The document will identify program descriptions requiring Research.gov preparation and submission and the associated effective date. This document will be updated on an ongoing basis as FastLane will be removed from all program descriptions as a proposal preparation and submission option when the PAPPG goes into effect in January 2023.
Since many program solicitations also require submission in Research.gov, proposers should pay close attention to the requirements identified in those specific funding opportunities.

Research.gov Proposal Capabilities and Transition from FastLane Proposal Preparation
Nearly all FastLane proposal preparation and submission capabilities are now available in Research.gov. For details about the remaining proposal features that will soon be added to Research.gov, please see the Proposal Submission Capabilities table on the Research.govAbout Proposal Preparation and Submission page. To stay informed about Research.gov and FastLane changes, we invite you to join our System Updates listserv. Sign up by sending a blank email to: system_updates-subscribe-request@listserv.nsf.gov.
NSF strongly encourages proposers to prepare and submit all supported proposals in Research.gov now, to facilitate a smooth transition from FastLane proposal preparation to Research.gov over the next several months. In addition, NSF relies on your vital feedback to help ensure the system is working as intended and to identify areas of improvement. Feedback may be submitted at https://www.research.gov/research-web/feedback.

Research.gov Proposal Preparation and Submission Training Resources

Questions? If you have IT system-related questions, please contact the NSF Help Desk at 1-800-381-1532 (7:00 AM – 9:00 PM ET; Monday – Friday except federal holidays) or via rgov@nsf.gov. Policy-related questions should be directed to policy@nsf.gov.

Federal Funding: Implementation of the New SAM Unique Entity Identifier (UEI) to Replace DUNS

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On February 7, 2022

In Federal Agency Announcements, Federal Regulations, Policies

The federal government is implementing a new “Unique Entity Identifier (UEI)” to replace the current DUNS number used to identify and validate federal contractors. This implementation will be effective April 4, 2022.

Although the implementation isn’t until April, many federal agencies (including the National Science Foundation) have begun the transition from the use of the DUNS number to the UEI, so you may be asked to include this number on your federal grant applications moving forward. As April gets closer, you will see more and more federal agencies replace the DUNS requirement with the UEI requirement.

Emerson’s UEI is JQMBE83BZHY6.

If you have any questions, please feel free to contact ORCS.

Issuance of NSF Proposal and Award Policies and Procedures Guide (NSF 22-1)

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On June 28, 2021

In Federal Agency Announcements, Federal Funding, Federal Regulations, Policies

The National Science Foundation has issued a revised version of the NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 22-1). The new PAPPG will be effective for proposals submitted or due on or after October 4, 2021. Significant changes include:

  • A new section covering requests for reasonable and accessibility accommodations regarding the proposal process or requests for accessibility accommodations to access NSF’s electronic systems, websites and other digital content;
  • A table entitled, NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support. This table identifies where pre- and post-award current and pending support disclosure information must be provided. Proposers and awardees may begin using this table immediately;
  • Increasing the page limit for the biographical sketch from two to three pages;
  • Updates to the current and pending support section of NSF proposals to require that information on objectives and overlap with other projects is provided to help NSF and reviewers assess overlap/duplication;
  • Adding planning proposals and Career-Life Balance supplemental funding requests as new proposal types;
  • Updates to travel proposals will require that AORs certify that prior to the proposer’s participation in the meeting for which NSF travel support is being requested, the proposer will assure that the meeting organizer has a written policy or code-of-conduct addressing harassment.

NSF plans to conduct a webinar covering these changes. Visit the NSF policy outreach website to sign up for notifications about this and other outreach events.

While this version of the PAPPG becomes effective on October 4, 2021, in the interim, the guidelines contained in the current PAPPG (NSF 20-1) continue to apply. 

If you have any questions regarding these changes, please contact the DIAS/Policy Office at policy@nsf.gov.

Research and Creative Scholarship in the News: Spring 2021

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On April 30, 2021

In Cool News and Trending Stories, Federal Regulations, Policies, Scholarship and Research

Biden Made a Promise to Scientists. He Can Still Keep It.
Researchers who receive federal help consistently fail to report their results to the public. The government should hold them accountable.

Mellon Foundation to Fund Diversity Programs at Library of Congress
The library will start an initiative, called “Of the People: Widening the Path,” which will encourage diversity among future librarians and archivists. The program is funded with a $15 million grant from the Andrew W. Mellon Foundation, part of a shift by the foundation toward issuing art and humanities grants through what it has called “a social justice lens.”

In the News

Arkansas Professor Is Accused of Hiding Chinese Funding
The professor kept the financial arrangements secret, allowing him to secure other grants from American government agencies that the Chinese funding made him ineligible for.

Key Changes to the OMB’s Uniform Guidance For Federal Awards

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On January 23, 2021

In Federal Funding, Federal Regulations, Policies

Uniform Guidance Basics

First implemented in 2014, the Office of Management and Budget’s (OMB) “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al), provides guidance to federal grantmaking agencies and applies to all federal awards received by Emerson College for research, scholarship, and other projects. The Uniform Guidance (UG) consolidated and replaced eight OMB Circulars such as the A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements). Federal agencies (NIH, NSF, NEA, etc) have each developed their own agency-specific implementation plans for the Uniform Guidance.

What’s Changed

On November 12, 2020, OMB implemented its Final Guidance on amendments to the OMB Guidance for Grants and Agreements. Overall, these changes give agencies more flexibility in designing and monitoring programs, as well as encouraging the use of data collection and analysis to identify best practices.

Key Changes for Emerson and Principal Investigators (PI’s) on Federal Awards

  • “Must” Vs. “Should.” Section §200.101(b)(1) clarifies that when the word “must” is used it indicates a requirement. Whereas, use of the word “should” or “may” indicates a best practice or recommended approach, and permits some discretion.
  • SAM.Gov Registration. SAM.gov registration numbers will be replaced with the new Unique Entity Identifier (UEI), and current SAM registrants will receive a UEI automatically. The UEI transition timeline was recently be extended to April 2022. DUNS numbers will be phased out for new registrations. SAM will retain DUNS numbers for historical purposes.
  • Subaward Reporting. The reporting threshold for subawards, under the Federal Funding Accountability and Transparency Act (FFATA), has increased from $25,000 to $30,000.
  • Prohibition on Certain Telecommunications Equipment and Services. Federal funds may not be used to make purchases from Huawei Technologies Company or ZTE Corporation and their subsidiaries 
  • Methods of Procurement. The micro-purchase threshold was raised from $3,500 to $10,000; the simplified acquisition threshold was raised from $150,000 to $250,000.
  • Domestic Preferences for Procurements. Grantees are encouraged to maximize the use of goods, products, and materials produced in the United States when procuring goods and services under Federal awards.
  • Monitoring and reporting program performance. Grant reporting requirements may become more stringent; granting agencies are required to more actively monitor progress on certain discretionary research awards.
  • Termination. Granting agencies are given more latitude in terminating an award when it is not meeting “program goals” or “agency priorities.”
  • Extended Closeout Dates. Final performance reports are now due 120 calendar days after the performance end date.
  • Publication and Printing Costs. The New guidance clarifies that any printing and publishing costs may only be charged to a federal grant if the award is in its final budget period.

For an annotated breakdown of all the changes, check out the Council on Governmental Relations’ (COGR) Implementation and Readiness Guide for the OMB Uniform Guidance.

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