The Department of Health and Human Services (HHS) and the National
Institutes of Health (NIH) have indicated a willingness to consider
applying a 15% “VA-add on” to the negotiated indirect cost rate for NIH
grants administered by affiliated universities on behalf of VA
investigators. The 15% VA-add on would be provided in addition to
university administrative off campus rates—capped at 26%—when work
associated with NIH grants is performed in VA facilities. This plan can
be considered a win-win model with universities maintaining their normal
reimbursement for administrative costs and the VA receiving
reimbursement for some of its infrastructure costs of supporting NIH-sponsored
research in VA facilities.
Background
In recent years, some VA-affiliated nonprofit research corporations (NPCs)
have obtained HHS-approved indirect cost rates—referred to as Facilities
and Administration (F&A) rates - and are administering NIH grants for VA
researchers (NPCs at San Francisco and San Diego among others).
Historically, however—and more commonly—VA-affiliated universities
administer NIH grants on behalf of VA investigators. When work on grants
is conducted in VA facilities, NIH provides the recipient university
with its negotiated off-campus indirect cost rate for the administration
component of the university's costs.
Current HHS policy does not allow reimbursement of grant related
indirect costs incurred by federal agencies. This has been interpreted
to preclude NIH from reimbursing VA hospitals for costs incurred in
support of NIH-sponsored research grants. As a result, VA medical
centers typically support the indirect costs associated with NIH
research conducted in VA facilities.
15% VA Add-On: To address this imbalance, NAVREF recommends
implementation of a mechanism that would allow HHS to add 15% to a
university's off-campus F&A rate. Funds generated under this rate would
be used to reimburse the affiliated VA medical center for its
incremental costs for such items as custodial services, waste disposal,
research space upgrades and maintenance, safety training/monitoring,
library, telephone and various support services such as warehouse, mail,
and WOC processing, etc., which are incurred as a result of NIH-sponsored
research conducted in the VA facility. The VA-add on rate would be
applicable only in instances where local choice and circumstances
dictate that the university (rather than the VA-affiliated corporation)
acts as the grant recipient, and the majority of the work on an
individual grant is conducted in a VA facility.
- Various VAMCs that have applied to HHS for a VA-add on in
conjunction with their affiliated universities (White River Junction,
Seattle, West Haven, Houston) have provided sufficient justification
for reimbursement ranging from 14.5% to 18%.
Based on these
detailed analyses, a flat national rate of 15% is recommended.
Notably, a 15% overhead rate is routinely provided on NIH/VA
interagency agreements (these are contracts, not grants, so HHS rules
do not preclude reimbursement). This establishes precedents for 1) the
15% rate; 2) the notion that VA medical centers can receive and retain
locally reimbursement for indirect costs on NIH-sponsored research;
and 3) recognition that the sponsoring agency should support the
direct and indirect costs of its own research.The VA
add-on would strengthen the university-NIH-VA partnership.
Universities still would receive and retain their off-campus rate. By
supporting some of the indirect costs of its own research, NIH would
benefit from VA's increased ability to support research. Also, VA
would be in a better position to support NIH-sponsored research as a
result of having funds available to relieve some of the pressure
research imposes on the medical care appropriation and to improve
research infrastructure.During 2001, the VA-add on would have
generated nearly $30 million for VA medical centers to cover a portion
of the costs that currently are being supported by VA's medical care
appropriation. Last year, VA investigators received NIH
grants totaling about $350 million. VA has calculated that typically
44% ($154 million) of NIH awards to VA investigators are conducted in
university facilities and presumably qualify for the university's
on-campus F&A rate. If applied to the 56% ($196 million) conducted in
VA facilities, the 15% VA-add on rate would have generated a cash flow
of nearly $30 million last year.
Funds generated by the VA-add on would flow from NIH to universities
to VA medical centers. It is anticipated that VAMCs would have to
demonstrate that the funds are expended in ways consistent with HHS
regulations (i.e., for research support), just as HHS requires
accountability on F&A expenditures from universities.University
stakeholders are communicating to HHS/NIH their support for the VA-add
on. The following institutions have sent letters to HHS and NIH or
have indicated that they will send letters shortly:
-
Stanford University
- Loyola University
- University of Washington School of Medicine
- Dartmouth Medical School
- Yale University School of Medicine
- University of Minnesota Medical School
|
- University of Texas Health Science Center at San Antonio
- University of California, Los Angeles School of Medicine
- University of Florida College of Medicine
- University of New Mexico Health Sciences Center
|
Action Needed
Additional academic affiliates of VA medical centers are encouraged to send
HHS/NIH letters of support.
Click here for a sample letter.
Letters should be addressed as follows:
Ms. Carol
Tippery, Acting Director
Office of Policy for Extramural
Research Administration (OPERA)
National Institute of Health (NIH)
6701 Rockledge Drive, MSC 7730
Bethesda, MD 20892-7730 |
Mr. Joe
Cook, Director
Office of Audit Resolution and Cost Policy
Department of Health and Human Services (DHHS)
200 Independence Ave. SW 522E
Washington DC 20201 |
Questions or comments regarding the VA-add on may be directed to
NAVREF Executive Director Barbara West. Phone: 301-229-1048. Fax:
301-229-0442. Email:
navref@navref.org. Thank you for your interest.