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Oklahoma State University
Oklahoma State University’s Cognizant Agency is the Office of Naval Research (ONR). Our current F&A rate expires June 30, 2015. However ONR, when issuing the negotiated rate for fiscal year ’13, ‘14, and ’15 also included a “provisional rate” for FY ’16. The provisional rate is a continuation of the FY ‘13-‘15 rate.
• OSU’s next F&A proposal is due in the Winter of 2015, and our proposal will use FY14 as the base year.
• Because of a University-wide implementation of an ERP system, major changes with Uniform Guidance Issuance, and the implementation of an Sponsored Program submission module, OSU would like to exercise the provisional rate already authorized for FY16. However the provisional rate was put into place as a management strategy for ONR—not necessarily for the benefit of the University. ONR is currently understaffed and expects delays in finalizing negotiations of F&A rates. By stipulating a provisional rate in the previous negotiations, ONR has provided themselves an extension in meeting negotiation deadlines.(As a side note, a “provisional rate” was issued for our Fringe Benefit rate which expired June 30, 2014 when the FB FY14 negotiation was completed in the Summer of 2013. As of October 1, 2014—after our FB proposal was delivered in January of 2014, we continue to wait on a final negotiated rate and continue to operate on our provisional rate issued in FY13).
Regarding our FY16 F&A proposal and the possible exercise of the provisional option, ONR has stated that “ONR will not negotiate the use of the provisional rate unless OSU provides data from the FY14 base year.” Essentially, if OSU’s FY14 base year data reflects a F&A rate (effective FY16) that is less than the provision rate offer, ONR will not allow the provisional option to continue into FY16. If the FY14 base expects an increase, the changes of the provisional rate quite possibly left in place. While 200.414(g) of the new Uniform Guidance does allow for a “one-time extension,” our FY16 proposal is technically due prior to the December 26, 2014 implementation of the Uniform Guidance.
• OSU uses Maximus and their CRIS software for proposal development.
• Traditionally, OSU has negotiated directly with ONR.