F&A Rates Awards & Proposals Implementation Guidance

The following implementation guidance applies to all sponsored awards/proposals with the exception of:

• Awards/proposals in which statutory limitations prevent some Federal sponsors from reimbursing F&A costs at the Federally- negotiated rates
• Awards/proposals from sponsoring agencies (state, local, and private) that have policies concerning the reimbursement of F&A costs at less than the Federally- negotiated rates
• Awards/proposals with an approved F&A Wavier

As sponsored awards/proposals such as the ones described above do not use the Federally-negotiated rates to begin with and therefore, the change in F&A rates does not impact those projects.

New, Renewal and Supplemental Proposals

Principal Investigators (PIs) and their staff should begin using the new F&A rates in new, renewal and supplemental (competing continuation) proposals immediately.  For competitive segments (i.e., the period of years, project years, approved by the funding agency at the time of the award, usually three to five years) the rates will be updated when the segment renews. 

To ease the transition for proposals that must be submitted to the sponsoring agency within 2 business days of GSU’s announcement of the new F&A rates, OSP staff will temporarily continue to endorse proposals reflecting the old F&A rates; however, all proposals with agency deadline dates over 2 business days from the time of GSU’s announcement of the new F&A rates must use the new rates and update all budget documentation.

New, Renewal and Supplemental Proposals Submitted but not Yet Awarded

To ensure that direct costs available to PIs are not adversely impacted by this rate change, awards received prior to the new F&A rates announcement and new, renewal or supplemental proposals submitted to the sponsor prior to the new F&A rates announcement will, when necessary, be accepted using the F&A rate contained in the submitted proposal. OSP will, however, work with agencies to increase F&A costs to the new rates wherever possible. Whichever F&A rate is finally awarded will subsequently be used throughout the competitive segment of that award.

Existing Awards and their Non-Competitive Proposals

All existing awards and their associated non-competitive continuation proposals will continue to use the F&A rate in effect at the time of their initial award (or most recent renewal) throughout the remainder of their competitive segment. This is necessary because governmental regulations require fixed rates over the life of a sponsored agreement and define “life” as each new competitive segment.

Example of F&A Rates to use for New, Renewal, and Supplemental Proposals vs. Non-Competitive Proposals

To illustrate, new or competitive renewal on-campus research proposals submitted on or after the announcement of the new rates should use the new Research F&A rate(s), FY 13 47.5% and FY 14 48%. However, non-competitive on-campus research continuations will continue to use the old Research F&A rate of 44.5% included in their most recent new or renewal award until the end of their multi-year project period (i.e. competitive segment). If a renewal proposal is then submitted for that project, it should use the new rates. In most cases proposals for additional funding, for example supplemental proposals, on existing projects will also use the new rates.