Say Hello, Waiver Goodbye

In a department, administrators and PIs have a lot of room to negotiate with other institutions when it comes to budgets involving awards and subcontracts.  Personnel effort?  That’s a classic.  Materials and supplies?  Probably your first stop.  Indirect cost percentage?  Slow your roll, holmes.

 

If the project is federally-sponsored, chances are slim that you’ll be successful in  your quest F&A reduction below our negotiated 54%*.   There are times when a lower F&A rate is acceptable without waiver/permission; for instance, the funding opportunity announcement caps the rate at lower than our negotiated rate, or the award is being transferred from another entity with direct cost equivalency.  Anything else requires a waiver with approval from the Vice Dean and SPA.  You cannot negotiate a reduced F&A on your own.

 

Here at Wayne State, the waiver request process begins with an IDC Waiver form. The Research Administrator and the PI should initiate the request, and it must be approved by the PI, the department chair, and the Vice Dean for Research before being sent for approval to SPA. The Vice Dean for Research will consider requests for Indirect (F&A) cost waivers in very limited circumstances, so be sure your justification is sound.  Here are some examples that may be considered on a case-by-case basis:

  • Capped awards
  • Seed grants which may attract larger awards
  • Only available source of funds in an area
  • Strategic partnerships
  • Awards which include equipment or building funds

 

If you’re just trying to make a proposal look more competitive, or  the PI/department failed to submit the proposal via approved institutional channels (e.g., through the Vice Dean or SPA) prior to submission to the sponsor, you’re out of luck.  Wayne State’s acceptance of an award with an unapproved F&A reduction does not constitute acceptance of the rate.  If you are awarded with a reduced F&A that was not properly approved, you must renegotiate at the time of award, otherwise the department will be responsible for cost-sharing the portion of the F&A not paid by the sponsor.

 

Questions?  You know where to find us!

 


* 54% is our federally-negotiated rate at the time of this post.

No Such Thing as a Free NCE

In case you missed it, Joe Schumaker wrote a good piece this month aligning requests for no cost extensions with the classic Dickens novel, Oliver Twist.  Here’s your bottom line: there can only be one (yes, that was a Highlander reference riffed from a Dickens reference.  All about the classics today, folks).

 

NIH provides an “expanded authorities” clause in almost all Standard Terms of Award that waives the requirement for prior approval No Cost Extension (NCE), among other actions.  If the text of the award allows, the grantee is permitted one NCE (that is, to extend the final budget period of a grant’s project period by up to 12 months, with no new funds).  This is usually done within 90 days of project end, when the Extension link appears in the “Action” column of the “Status” search results screen. Anything beyond that one request will require permission.

 

As NIH adjusts NCE guidelines to meet the requirements outlined in the Uniform Guidance, they have audibly noticed an increasing trend of people asking for NCEs in the middle of the project period. You can do this, but this is your one shot.  That is: if you get a permitted NCE in the middle of your project period, you won’t see your Extension link at the end of your project period;  you’ve already used your expanded authority, even though you had to obtain permission to do so.  Further, if you choose not to use the entire allowable 12 months (like you ask for, say, a 4 month extension), you can’t ask for the remainder of what’s allowable (8 months, in this case) without permission: it still counts as a second extension.

 

So, Warriors, be careful what you wish for; beyond that, know what you’re wishing for.  If you’re unsure of your best strategy, let us know: we’ll help you talk it out and figure what’s best for you!