The document, prepared by the Council on Governmental Relations (COGR), examines the significant challenges and emerging considerations affecting Facilities and Administrative (F&A) cost rates and reimbursements for research institutions during and after the COVID-19 pandemic. It details how the pandemic has disrupted traditional processes for developing F&A cost rate proposals, especially for fiscal years 2021 and 2022, due to atypical operational and financial conditions such as increased costs for health and safety measures, changes in space utilization, shifts to remote work, and institutional cost savings through furloughs and spending reductions. The report advises institutions to assess the impact of COVID-19 through trial runs of F&A calculations and to consider strategic communication with federal cognizant agencies (primarily DHHS-CAS and ONR) to ensure fair and equitable rate setting, whether through proposing new rates, requesting extensions, or adopting provisional rates.
Beyond immediate issues, the report explores prospective, possibly permanent changes to research infrastructure and F&A processes. It notes ongoing financial pressures due to reduced revenues and evolving space needs, recommending that institutions carefully model these shifts and evaluate their effects on both costs and cost allocation. The document addresses regulatory developments, such as new data sharing requirements and cybersecurity certifications, that could further impact administrative burdens and cost structures. Appendices provide additional guidance on space metrics, service center deficits, and fringe benefit rate implications under pandemic conditions. Emphasizing the importance of a transparent and collaborative federal-institutional partnership, the report concludes that maintaining a reliable, equitable F&A reimbursement system is vital to sustaining the U.S. research enterprise in the face of ongoing uncertainties and structural changes sparked by the pandemic.
