Budgeting Indirect Costs

Purpose

These are the established NIU policies and procedures regarding the recovery of indirect costs on sponsored projects.

Reason for This Policy

Costs on sponsored projects (grants or contracts) can be divided into two overarching categories:

1. Direct costs
2. Indirect costs

Direct costs can be readily and specifically attributed to the scope of work associated with a particular project or program. As such, direct costs may include salaries and benefits associated with personnel who dedicate time and effort to conducting the work; supplies and equipment required to perform the work, and professional travel associated with completion or communication of the work. Indirect costs - previously referred to as facilities and administrative cost - cannot easily be associated with a given project or program; nonetheless, these are real expenses incurred by the university in support of sponsored research and artistry.

Indirect costs result from the university’s need to maintain a shared infrastructure that supports the research, scholarship, service and artistry of all investigators and project directors. Examples of indirect costs include facilities costs (e.g. building depreciation, operation and maintenance, utilities, telecommunications and IT infrastructure, libraries, and specialized facilities and services) and administrative costs (e.g. personnel and infrastructure associated with sponsored project administration (SPA, Innovation, Research Compliance) and with other administrative functions of the university (general accounting, purchasing/procurement, legal services, human resources, administration of academic units).

The University negotiates its indirect cost rates with the U.S. Department of Health and Human Services Cost Accounting Services (CAS).

Federal and state laws and regulations require that NIU’s federally approved indirect cost rate be applied consistently to all sponsored projects, and the university is scrutinized for compliance. In addition, state and university policies strongly encourage NIU investigators to perform sponsored work on a full cost recovery basis unless restricted by law or public policy. Projects that bring in less than the full amount of indirect costs represent a subsidy of the sponsor by the University. In many cases, such subsidies run counter to federal accounting rules, as well as University and State interests. Failure to recover allowable direct costs and indirect costs reduces the university’s capacity to perform sponsored research and support faculty scholarship.

Intended Audience

• Dean
• Senior Administration – Vice Provosts, Associate Deans 
• Director, Department Chair, Division Head 
• Faculty and Staff
• Departmental/Divisional Business Administrators
• Finance Personnel
• Sponsored Programs Administration Personnel

Policy

It is the policy of Northern Illinois University to apply the University’s full indirect cost rate to all externally funded projects. Externally funded projects include those projects where NIU is both a direct recipient of the funds and a subrecipient or contractor.  

In accordance with the policy:

• Only the Vice President for Research and Innovation Partnerships (or designee) is authorized to modify indirect cost rates for a given project. Investigators and Project Directors are not authorized to modify the indirect cost rate. Any “prior understanding” between an investigator and a sponsor regarding these rates is not binding on the university.
• The on-campus indirect cost rate is applied unless it can be established that a majority of the project will be conducted in an off-campus location consistent with the University’s negotiated indirect cost rate agreement. Proper campus designation of a sponsored project is necessary to ensure the university is not over-charging or under-charging a sponsor for project costs.
• A limitation on the amount of funds available for a project from a sponsor is not in and of itself sufficient justification for a reduction or waiver of full indirect costs.
• For-profit sponsors will not be charged less than the federally negotiated indirect cost rate. As a nonprofit, public research university, it is inappropriate for NIU to allow its funds and facilities to subsidize projects conducted for the benefit of commercial sponsors. Investigators who are concerned about requesting the federally negotiated rate from a private sponsor are encouraged to contact SPA for budgeting strategies. 

Indirect Cost Exceptions

The appropriate, approved indirect cost rate will be sought on all sponsored projects regardless of funding source. All sponsors are expected to pay full costs except where prohibited due to legislative, regulatory, or programmatic restrictions. Federal programs restricting full indirect recovery will identify the limitation in the Funding Opportunity Announcement (FOA).

Examples of Federal programs that may limit F&A include:

• Training grants
• Conference and travel grants
• Career development grants 

If a government or non-profit sponsor has a published, consistently applied policy establishing a specific indirect cost rate for their project(s), NIU will honor that rate.

In the absence of a published rate, NIU’s federally negotiated indirect cost rate will take precedence.

If a for-profit sponsor requires full ownership of intellectual property produced jointly under a grant or contract and these conditions are consistent with the investigator’s expectations, then an indirect cost rate significantly greater than the federally negotiated rate (up to 200%  rate) may be applied to the total project costs as specified by the Vice President for Research and Innovation Partnerships. It is inappropriate for NIU to allow its funds and facilities to subsidize projects conducted solely or primarily to benefit commercial sponsors. Relevant examples of intellectual property may include the following:

• New or improved devices
• Circuits
• Chemical compounds
• Drugs
• Genetically engineered biological organisms
• Data sets
• Software
• Musical processes
• Unique and innovative uses of existing inventions

Indirect Cost Waivers

On a case-by-case basis, the Vice President for Research and Innovation Partnerships (or designee) may approve a reduction or complete waiver of indirect costs given sufficient justification. Indirect cost waivers are rare.

The following circumstances will be considered as part of any request to reduce or waive indirect recovery.

• Selected start-up projects where it is anticipated that the collaboration will result in future growth of external funding.
• Cases wherein indirect costs is an eligible category of cost-share.
• Cases wherein the benefit to the University outweighs the loss of indirect recovery. For example, the project represents an important university outreach effort or a mandated activity that the university would otherwise be paying for.
• Cases wherein 80% or more of the project budget involve student assistantships and materials and supplies that support student activities.

Roles and Responsibilities

Principal Investigator - Ensure the appropriateness of all charges on sponsored projects. Determine if it is appropriate to request an indirect cost rate reduction and initiate the waiver request to the Division of Research and Innovation Partnerships.

Department Chair or Unit Head or Designee - Establish effective processes and controls to ensure compliance with this policy. Communicate these practices to faculty and unit personnel. Evaluate indirect cost reduction requests taking into consideration the unit’s fiduciary responsibilities to the University.

Dean or Division Head or Designee - Establish effective processes and controls to ensure compliance with this policy. Communicate these practices to faculty and division personnel. Evaluate indirect cost rate reduction requests taking into consideration the college or division’s fiduciary responsibilities to the University.

Vice President for Research and Innovation Partnerships or Designee - Evaluate all requests for indirect cost reductions and waivers and approves or denies them.

Sponsored Programs Administration - Support Principal Investigators with determining the appropriateness of charges on sponsored projects. Assists in the interpretation of federal regulations and other agency policies guiding the application of indirect cost rates. Develop and maintain policies and procedures in accordance with this policy and applicable regulations. Retain documentation of approved reductions or waivers.