15.2 Facilities and Administrative (Indirect Cost) Waivers
Establishes policy to apply the University's full negotiated indirect cost rate to all externally-sponsored projects by categories defined in RPH: Categories of Sponsored Projects. Presents procedures to apply for a waiver of that rate for specific proposals, and criteria on which waiver decisions are made.
2. Roles and Responsibilities
The fiscal management of sponsored projects, including the application of appropriate indirect cost rates in proposed project budgets and management of awarded projects within budget and funding limitations, is the responsibility of the PI.
In certain circumstances, the Vice Provost and Dean of Research may approve full or partial waivers of the F&A costs normally incurred by sponsored projects. However, such waivers will not be considered for projects where the sponsor is:
- a for-profit organization, whether US or international
an office or agency of a foreign government, including organizations funded by that government
4. Pre-Approved Exceptions
Some programs or sponsors are pre-approved by Stanford for a waiver of a portion or all of our normal F&A cost recovery. In most cases, these programs or sponsors require such a waiver as a condition of the award. The Office of the Vice Provost and Dean of Research maintains a list of such programs and sponsors.
Stanford recognizes that many non-profit foundations have their own policies regarding the use of their funds for overhead expenses. In the case where the foundation has an official written and publicly disclosed policy in this regard that is applied on a consistent basis, or where a public solicitation for proposals defines a limit on indirect cost recovery as a condition of the program, Stanford will normally accept those requirements. The foundation's policy statement or program solicitation should be submitted to the OSR as an attachment to the Proposal Development & Routing Form (PDRF) as part of the completed proposal package.
Note: In cases where Stanford's agreement to accept a lower F&A cost rate is based on our understanding of the sponsor's policy, and where Stanford becomes aware of a higher indirect cost rate paid by that sponsor to another recipient, the university reserves the right to apply the higher rate to that sponsor's Stanford projects.
Keep the following in mind when preparing a proposal to a non-profit foundation:
- For some foundations, Stanford requires clearance through its office of Corporate and Foundation Relations prior to submission of any proposal. See below in Related Items: The Office of Foundation Relations website.
- In the case of foundations based outside of the United States, or those established as an arm of a for-profit organization, indirect cost waivers will not be pre-approved; such requests will be considered only on a case-by-case basis (see below). In these cases, care must be taken to determine the non-profit status of the sponsor, and the PI should confer with OSR in advance to determine the applicability of indirect costs.
- Indirect costs will not normally be waived solely because a foundation has expressed a desire to limit the use of its funds for a particular award to Stanford. Unless the program solicitation includes such a limitation for all recipients, or the foundation has an official written and publicly disclosed policy in this regard, a waiver will not be pre-approved. In such cases, a case-by-case waiver may be requested (see below).
5. Case-by-Case Exceptions
The Dean of Research will consider other requests for indirect cost waivers only in very limited circumstances. [NOTE: This approval authority is delegated to the Dean of the School of Medicine for projects to be administered within the School of Medicine.]
Special requests are initiated by the PI and must be approved by the PI's department chair and school dean's office before being sent for approval to the Dean of Research. The decision whether to grant or deny an exception request is at the sole discretion of the Dean of Research, or the Medical School Dean for projects in that school. In determining the institutional costs and benefits of such requests, the Dean of Research may take any or all of the following into consideration:
- The equity of granting the waiver when the projects of other faculty carry full overhead
- The total cost to Stanford
- The likelihood that an award would be seriously jeopardized without a waiver, and the potential effect of the loss on the faculty member's overall research program
- The benefit of the waiver to new or junior faculty members or in support of research efforts in new directions which otherwise might not be sufficiently developed to attract typical peer-reviewed awards
- The effect of a waiver to increase direct costs available for student support
Outside of the School of Medicine, requests for indirect cost waivers are submitted using the form found below in "Related Items".
6. Infrastructure Charge Policy
A waiver of indirect cost recovery under the terms of this policy does not waive the University's infrastructure charge collected on the expenditure of restricted dollars.
The application of the infrastructure charge and specific exemptions are discussed in Administrative Guide Memo 37.3. See below in Related Items.