The document, authored by the COGR Costing Committee and published in 2010, provides a detailed analysis of various arbitrary cost reimbursement policies imposed by federal funding agencies that impact research institutions’ ability to recover full costs associated with federally funded research and projects. It highlights specific examples from multiple agencies, such as NIH, NSF, NASA, the Department of Education, and others, illustrating a range of limitations including caps on Facilities and Administrative (F&A) rates, salary limitations, cost-sharing requirements, selective reimbursement of project costs, and statutory mandates on indirect cost recoveries. These policies often deviate from negotiated rates and established institutional practices, leading to significant financial burdens on research institutions, sometimes amounting to millions in subsidized costs each year.
The appendix further underscores the administrative complexity resulting from these varied and sometimes inconsistent policies, noting that compliance can require extensive manual tracking and management. The cumulative effect is an increased financial and operational burden on institutions, which may threaten their ability to sustain research activities and adequately support faculty, staff, and trainees. The document calls attention to the mismatch between the actual resources universities must expend and the reimbursement provided, arguing for more consistent and equitable federal policies that reflect the true costs of research and emphasize the importance of full cost recovery for maintaining a vibrant research enterprise.
