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F&A Rates Subcontracts & Carry Forward Implementation Guidance

Subcontracts under Federal Grants and Contracts 

FOR RESEARCH AND PUBLIC SERVICE:
F&A rates for subcontracts under federal grants and contracts with start dates prior to July 1, 2012 will remain fixed for the life of the prime agreement (i.e., through the competitive segment of the prime award) at the rate specified in the prime award.

New subcontracts with a start date of July 1, 2012 or later should use the appropriate new F&A rate.

However, if a new subcontract award with a start date of July 1, 2012 or later is received which has been issued at the old F&A rate, the PI or department administrator will need to coordinate with OSP on procedures for requesting the new DHHS rates from the subcontracting agency. Should the subcontracting agency deny the request, exceptions may be granted on a case-by-case basis by OSP to allow use of the expired rates.

FOR INSTRUCTION:
F&A rates for subcontracts under federal grants and contracts with start dates prior to July 1, 2011 will remain fixed for the life of the prime agreement (i.e., through the competitive segment of the prime award) at the F&A rate specified in the prime award. 

New subcontracts with a start date of July 1, 2011 or later should use the appropriate new F&A rate.

However, if a new subcontract award with a start date of July 1, 2011 or later has been or is received which has been issued at the old F&A rate, the PI or department administrator will need to coordinate with OSP on procedures for requesting the new lower DHHS rates from the subcontracting agency.

Treatment of Carry Forward of Unobligated Balances Requiring Sponsor Approval

Sponsors consider carry forward of unobligated balances requiring their approval as new awards. Therefore the F&A rate to be used on these awards are based on the issuance date of the new award/authorization.

Use of Old F&A Rate 

For Research and Public Service carry forward awards with issue dates prior to July 1, 2012, the appropriate old F&A rate will be sustained through the completion of the current competitive segment of the award.  For Instruction carry forward awards with issue dates prior to July 1, 2011, the appropriate old F&A rate will be sustained through the completion of the current competitive segment of the award.

Use of Old and New F&A Rates

For Research and Public Service carry forward awards with issue dates on or after July 1, 2012 but where the most recent competitive segment of the original award has a start date prior to July 1, 2012, a new speedtype/project number will need to be established to accomplish the proper charging of F&A costs for the carry forward balance. For Instruction carry forward awards with issue dates on or after July 1, 2011 but where the most recent competitive segment of the original award has a start date prior to July 1, 2011, a new speedtype/project number will need to be established to accomplish the proper charging of F&A costs for the carry forward balance.

F&A charges for the carry forward funds will be made at the appropriate new F&A rate whereas, F&A charges to the original awarded funds will be made at the appropriate old F&A rate through the completion of the current competitive segment of the awards.

Use of New F&A Rate

For Research and Public Service carry forward awards with issue dates on or after July 1, 2012 and where the most recent competitive segment of the original award has a start date on or after July 1, 2012, the appropriate new F&A rate will be used through the completion of the current competitive segment of the award.  For Instruction carry forward awards with issue dates on or after July 1, 2011 and where the most recent competitive segment of the original award has a start date on or after July 1, 2011, the appropriate new F&A rate will be used through the completion of the current competitive segment of the award.

Treatment of Automatic Carry Forward of Funds 

The automatic carry forward of funds, which do not require sponsor approval, into the next budget period within the same competitive segment will continue to use the F&A rate in effect at the time of the initial award (or most recent renewal) throughout the remainder of their competitive segment. 

However automatic carry forward of funds, which do not require sponsor approval, that cross over into a new competitive segment would function as a new award and use the appropriate new F&A rate through the completion of the current competitive segment.  

Announcement

March 1st, 2012 - Our F&A rates have changed.  Please review these pages to learn more.  The new F&A rate agreement can be found in the Downloads list below.