Use of On-Campus vs. Off-Campus F&A Rate
September 27, 2011 DHHS F&A Rate Agreement: "OFF-CAMPUS DEFINITION: For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s), the off-campus rate will apply. Actual costs will be apportioned between on-campus and off-campus components. Each portion will bear the appropriate rate."
A sponsored project designation indicating the general location(s) of the activity that will occur in conducting the project. Off-campus locations include space that the University does not own AND one of the following additional criteria: a) the space is remote from either the Evanston or Chicago campus, OR b) no University entity bears a lease cost for occupying the space. Factors indicating that a space is remote include significant physical distance from either campus, and use of separate (non-University) services such as mail, telephone, network and other support services.
The off-campus designation indicates that any reimbursement of facilities-related costs will occur directly, through a direct space charge, rather than indirectly through the application of a F&A rate that includes those costs. For most federal sponsors, the "off-campus" negotiated F&A rate (26% MTDC, representing only Administrative costs) applies to projects designated as off-campus. For many non-federal sponsors, the published non-federal off-campus F&A rate applies. Certain types of awards and/or sponsors stipulate specific F&A rates. In these cases, the off-campus designation is still appropriate but has no relation to the applicable F&A rate. For purposes of the F&A rate proposal, all direct expenditures on projects designated as off-campus are included in the same base.
Space in a building that the University does not own, but which the University occupies and for which a lease cost is borne. That lease cost may be borne by a central, school, or departmental CUFS account. When leased space is used to conduct a sponsored project, that project may be designated as either "on-campus" or "off-campus", based on defined parameters. The existence of a lease does not, in and of itself, indicate off-campus designation.
Leased space = on-campus when that space is contiguous or nearly contiguous to either the Evanston or Chicago campus. Factors indicating that a leased space is contiguous include physical proximity to either the Evanston or Chicago campus, and use of University-provided support services such as mail, telephone, and network services.
Leased space = off-campus when that space is remote from either the Evanston or Chicago campus. Factors indicating that a leased space is remote include significant physical distance from either campus, and use of separate (non-University) services such as mail, telephone, network and other support services. When a leased space is considered off-campus, a direct rent cost should be included in the proposal budgets and charged to benefiting sponsored projects.
When to Use the On-Campus Rate
- The on-campus rate applies to projects performed in space that the University owns, including but not limited to the 1801 Maple building.
- The on-campus rate applies to projects performed in leased space that is contiguous or nearly contiguous to either the Evanston or Chicago campus.
- Rent (recurring; i.e., not one-time or short-term facility rental) may not be charged to projects applying the on-campus rate.
When to Use the Off-Campus Rate
- The off-campus rate applies to projects performed in leased space that is remote from either the Evanston or Chicago campus. A direct rent cost should be included in the proposal budgets and charged to benefiting sponsored projects.
- The off-campus rate applies to projects performed in space that the University does not own and for which the University does not bear a lease cost from any University account (sponsored or non-sponsored, central or school/department fund source), whether that space is contiguous to or remote from the Evanston or Chicago campus. In these cases, a rental cost should not be direct charged to the project as there is no real cost to any University entity.
Determining Whether a Project should be Apportioned between the On- and Off-Campus Components
In select cases, the nature of the project entails activity in multiple locations. When those locations represent both on- and off-campus space (according to the criteria established above), and the proportion of off-campus activity reaches the threshold outlined below, then the project will be apportioned into the on- and off-campus components. Two sponsored project accounts will be established: one for the expenses associated with the on-campus activity and one for the expenses associated with the off-campus activity. The establishment of separate accounts will facilitate the assessment of the appropriate F&A rates. Costs should be charged to the respective accounts in accordance with the proposed and awarded project budget.
A project will be apportioned between its on- and off-campus components when it can be demonstrated that at least 25% of the total direct costs of the project relate to activity that will occur in space that meets the off-campus criteria. For purposes of measuring against this threshold, salary, wage and the associated fringe expense are considered off-campus when the project personnel are conducting the actual work in off-campus space. Non-labor expenses are considered off-campus when the goods/services are received and used in off-campus space. Subcontractor and consultant expenses are excluded from consideration; in all cases, subcontractor and consultant expenses are considered on-campus.
Travel expenses should be considered as follows:
- Travel expense incurred for travel between the University and the off-campus space is considered off-campus.
- Travel expense incurred for travel between the off-campus space and another off-campus location is considered off-campus.
- Travel expense incurred for travel between the University and a destination other than the off-campus space is considered on-campus.
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