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F&A Waivers

Last updated: 09/10/2021 - 9:43am

F&A Waivers

Why must Proposals include full F&A?

Insufficient funding for University facilities and administrative costs could reduce ASU’s ability to attract and/or increase external support.  Therefore, any request to reduce F&A will be carefully scrutinized to ensure the project significantly benefits ASU’s mission.

Will it impact the Investigators' department(s)/college(s)?

Yes.  No Research Incentive Distribution (RID) will be issued for projects with F&A waivers.

How long will it take for a decision from OKED?

The review process is not instantaneous and will vary according to OKED availability.  Do not wait until the last minute.  OKED is the only authorized office to grant waivers. OKED will not consider a request unless and until all PIs, Chairs, and Deans have agreed to the reduction.

Will ORSPA submit A proposal prior to the F&A waiver decision?

It is the principal investigator's responsibility to secure approval prior to sending the proposal to ORSPA for submission.

How long is the F&A waiver valid?

It is valid for the specific proposal and the directly resulting award period. When a new ERA funding proposal is processed (including Revision and Renewal proposals), any previous F&A Waiver(s) will not automatically apply. The new proposal budget should include one of the following: (a) ASU’s current, full F&A rate, (b) documentation of a published sponsor limitation on the F&A rate, or (c) a new F&A Waiver, which may or may not be approved. If questions arise regarding the appropriate F&A rate for a specific proposal, please consult with the Grant + Contract Officer (GCO) assigned to the proposal

Is the Sponsor on the List of Limited F&A Rates?

If the sponsor is included on the list of Limited F&A Rates, then no waiver or additional documentation is needed.

If not listed, then use the following decision tree to determine if the project is eligible to request an F&A waiver.

All proposals submitted, regardless if ASU does business with them frequently will need to include documentation of a Sponsor's limited rate restriction when submitting to ORSPA for review.

Is an F&A Waiver NEEDED?

 

How Is an F&A Waiver requested? 

Pre-Award F&A Waiver Requests:

The following process applies to both ASU/ORSPA and ASUF proposals.

  1. The PI provides a written justification–not to exceed 1 page– for inclusion on the form which explains:
    •    Budget - Why are we not able to use ASU's full F&A rate?
    •    Future Planning – If this project may be renewed in future, what steps are being taken to ensure that ASU’s full F&A rate will be utilized on future funding for this program?
    •    Diversity - Please describe any ways that this project will benefit and include historically marginalized populations.
    •    Charter - How does this project advance ASU's charter?
    •    Mission & Goals - How does this project advance ASU's mission and goals?
     
  2. The unit RA completes, in consultation with the PI, the required F&A Waiver Request SmartForm in ERA 
  3. The Unit RA will Generate F and A  Approvers and Submit for F and A Waiver Review

NOTES:  Waivers should not include salary for the PI and other senior personnel.  It is recommended that the funds for this expense be removed from the budget.   If included, the reason for why this project cannot be done without the salary is required to be part of the written justification.  Only with strong justification, and in rare circumstances, will this expense be approved.

Post-Award F&A Waiver Requests: In very rare circumstances, a waiver may need to be requested during the post-award period. For Post-Award F&A Waivers, the Unit RA should complete and route the F and A Waiver Request Form on the Forms and Templates page. The same justification requirements listed above for Pre-Award requests will apply to Post-Award waiver requests.

For general questions about when a waiver is appropriate, please contact RAHelp@asu.edu.   For assistance with processing the waiver in ERA, please contact ERA@asu.edu.

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