Recovery of Facilities and Administrative (F&A) Costs Policy

1. Purpose of Policy 

Western Michigan University seeks to recover full direct and facilities and administrative (F&A) costs on all sponsored projects unless published funding agency or program restrictions prohibit full recovery. F&A costs are expressed as a percentage of total direct costs minus exclusions; are agreed upon through formal negotiations on regularly scheduled intervals with the U.S. Department of Health and Human Services, WMU’s cognizant agency; and are based upon data presented by the University in a proposal prepared according to the agency’s instructions.

Should the University fail to recover the full costs of a project, there are two consequences. Not only does the University absorb the remaining cost but also University dollars subsidize the agency. In effect, the University limits its resources to the benefit of the agency.

2. Stakeholders Most Impacted by the Policy 

This policy applies to all research personnel (employees, faculty, students, research staff) applying for research and sponsored projects conducted under the auspices of Western Michigan University whether the research is conducted on or off campus.

3. Key Definitions 

3.1 Proposal approval form (PAF) – The PAF contains all the information necessary for the Office of Research and Innovation to submit a grant on behalf of the Western Michigan University. 
3.2 Facilities and Administrative Cost (F&A) – F&A costs are part of the funds awarded to the University to maintain the underlying research infrastructure such as the construction and maintenance of laboratories and high-tech facilities; energy and utility expenses; and safety, security, and other government-mandated expenses.  These also include, for example, utilities, custodial services, payroll, purchasing, and departmental administration.  

4. Full Policy Details 

The University will not accept awards that do not include F&A costs at the rate set forth in the University’s agreement negotiated with the U.S. Department of Health and Human Services, or as approved by the Vice President for Research and Innovation.

4.1 Western Michigan University recovers F&A costs according to type of sponsor, as follows:

• 4.1.1 Federal. Except as provided otherwise by federal regulations, proposals to and awards from federal agencies must include F&A costs at the rate set forth in the University’s agreement negotiated with the U.S. Department of Health and Human Services. Except as provided otherwise by federal regulations, F&A costs on federal flow‐through funds must be included at the appropriate federal rate.
• 4.1.2 Nonprofit, state, and other governmental bodies. Proposals to and awards from these entities must include F&A costs at the rate set forth in the University’s agreement negotiated with the U.S. Department of Health and Human Services.
• 4.1.3 For‐profit. Proposals to and awards from nonfederal for‐profit entities must include F&A costs at the rate set forth in the University’s agreement negotiated with the U.S. Department of Health and Human Services.

4.2 Communication

The policy was previously reviewed by both the Research Policy Council and the Research Advisory Team, and will be distributed via departments and colleges.

4.3 Exceptions

Any request for an exception must follow the Requesting a Facilities & Administrative Rate Waiver Procedure available on the OVPR website https://wmich.edu/research.

5. Accountability 

5.1 Consequences for failure to comply with the policy. The college or vice presidential area is responsible for ensuring that proposals are submitted according to these guidelines. Failure to comply with these guidelines could result in withdrawal of the proposal or the loss of distributed F&A recoveries.

5.2 Annual review of request‐for‐exception activity. The Vice President for Research and Innovation will review annually the cumulative activity for exceptions, to ascertain trends in college and unit requests and to evaluate college‐level effectiveness in recovering full F&A costs.

5.3 Additional consequences for non-compliance include possible individual disciplinary procedures for failure to follow applicable University policies and requirements.

6. Related Procedures and Guidelines 

See links to “Requesting a Facilities & Administrative Rate Waiver Procedure and other information under Facilities and Administrative Funds  (https://wmich.edu/research/policies)

7. Additional Information 

Grants and awards may only be signed by those individuals who have explicit signature authority granted by the Vice President of Business and Finance. 

8. FAQS

Question: I worked with the Office of Government Affairs and was told my funds were a one-time allocation from the State of Michigan, is there F and A applied to those funds?

Answer: It depends on the mechanism the state uses to direct the funds to WMU.  While the funds may be obtained as part of the annual state budget process, the State of Michigan sometimes still sends the funds in the form of a grant or contract to WMU.  Thus, these "appropriations" should include F and A when the budget is developed.  Please contact your research officer in OVPR for assistance.