Guidance for Application of F&A Dated 12/17/18

On 12/17/2018, the Department of Health and Human Services (DHHS) approved the Facilities and Administrative (F&A) rates for all Texas A&M University System Members headquartered in College Station for the period 09/01/2018 through 08/31/2022. The rates are posted on the System website.

In accordance with Uniform Guidance, College Station based members provided SRS guidance regarding implementation of the new rates. Uniform Guidance Appendix III Section C.7 states the following:

“Federal agencies must use the negotiated rates in effect at the time of the initial award throughout the life of the Federal award. Award levels for Federal awards may not be adjusted in future years as a result of changes in negotiated rates. “Negotiated rates” per the rate agreement include final, fixed, and predetermined rates and exclude provisional rates. “Life” for the purpose of this subsection means each competitive segment of a project. A competitive segment is a period of years approved by the Federal awarding agency at the time of the Federal award. If negotiated rate agreements do not extend through the life of the Federal award at the time of the initial award, then the negotiated rate for the last year of the Federal award must be extended through the end of the life of the Federal award.”

Scenarios

1. Awards issued prior to 12/17/18:

In compliance with Uniform Guidance, awards made prior to the issuance of the new F&A rate agreement, no changes will be made to the F&A for the life of the award. If there is a competitive segment, it will be proposed using the rates in effect at time of proposal.

2. Proposals submitted prior to announcement of new rates but awarded on or after 12/17/18:

For multi-year awards that have been received since the new rates were announced but were submitted using the previous F&A rates, SRS will work with sponsors and principal investigators to implement the applicable rates for the out years. In some cases, this may require re-budgeting but in other cases, the sponsors may increase the award amount to accommodate the change in F&A rates. SRS administrators are prepared to assist with this process.

3. Proposals submitted after the announcement of the new F&A rate:

Beginning January 2019, proposals have been prepared using F&A rates approved in the agreement dated 12/17/18. Budgets are being prepared by using the rate that is in effect based on the start date of the proposal, the same rate will be used for that entire budget year. For out years, the budgets will be prepared with the F&A rate that is in effect at the beginning of each of those budget years.

Example 1: On campus, basic research, three year proposal with a start date of 01/01/19

Year 1: 01/01/19 – 12/31/19 the F&A rate of 48.5% will be applied

Year 2: 01/01/20 – 12/31/20 the F&A rate of 50.5% will be applied

Year 3: 01/01/21 – 12/31/21 the F&A rate of 51.5% will be applied

Example 2: On campus, basic research, three year proposal with a start date of 10/01/19

Year 1: 10/01/19 – 09/30/20 the F&A rate of 50% will be applied

Year 2: 10/01/20 – 09/30/21 the F&A rate of 51.5% will be applied

Year 3: 10/01/21 – 09/30/22 the F&A rate of 51.5% will be applied