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Attachment 1
STANFORD UNIVERSITY
Office of the Associate Vice President for Research Administration
March 18, 1999
Ms. Diana Jaeger
National Institutes of Health
6701 Rockledge Drive
Suite 2188
Bethesda, MD 20892-7730
Dear Diana:
I understand that you had a meeting this
past month with staff from the Department of Health and Human Services
and the Veterans Administration (VA) regarding reimbursement for
facility and administrative costs (F&A) on grants for activities taking
place in VA facilities. I thought it might be helpful to provide some
background on Stanford's interest in this particular matter. First of
all, we want to continue to have Stanford University faculty who hold
dual University/VA appointments and whose laboratories are located at
our affiliated VA facility to apply for grants through the University.
The opportunity to create or engage in cutting edge research is a main
attraction for academicians at the Stanford University School of
Medicine and the VA Palo Alto Health Care System is an integral
component in this program. Further, the VA patient population is an
important group for many clinical trials conducted by our faculty and,
therefore, an important resource to NIH as well.
The principal reason that we are
interested in having Stanford University continue to be the grantee
institution is a programmatic one. We wish to ensure that all the
faculty, regardless of where they have their clinical appointment or
where they work, have access to equal support for their research
activities. We want the faculty to pursue their research through the
Medical School so the Dean and the Department Chairs have an
understanding of and oversight over all of the research activity of the
faculty, not just part of it. Further, by retaining administrative
responsibility for these grants, we assure that a single standard is
applied in the administration that supports this research, the
protection for human subjects, and the humane care of animals. We want
to minimize the perception that resources for those investigators and
laboratories located on campus are different than or richer than those
that are off campus.
When there is no support for VA
facilities' costs, this becomes a real challenge. The VA is supporting
the incremental facility costs associated with NIH supported grants of
Stanford faculty working at the VA. And, clearly there are incremental
costs associated with the conduct of research above and beyond the cost
of clinical care in these facilities such as utilities, operations and
maintenance, biosafety, etc. The costs are no different in that respect
than if they were occurring in Stanford-owned facilities. As VA budgets
shrink, so does the willingness and ability of VA administrators to
continue to bear this burden. So, of course, we believe that in order
to be equitable NIH should reimburse these facility and administrative
costs on the same basis, without distinction for the fact that they are
VA facilities.
I know that one of the stumbling blocks
has been whether the VA is authorized to receive reimbursement for
these incremental facility costs. I have been assured by colleagues
here that they can. I presume that the VA staff in Washington can
confirm that on behalf of all VA Hospitals.
So, we approach this issue with an
interest in receiving a reasonable reimbursement to the VA for the
incremental costs of research in their facilities through the Stanford
F&A rate. We are developing an off-campus VA specific rate for those
costs that we think are eligible for reimbursement. While we are
interested in a university-based F&A rate of reimbursement, it probably
would be comparable for those who are seeking to reimburse the VA for
research conducted through their affiliated foundations. We might even
be willing to entertain an "allowance" or a flat rate for the facility
portion of the costs, e.g.15 percent. We would add such an allowance to
our off-campus rate for administrative and library expenses for the
total reimbursement.
I hope that this background helps in
future discussions you may have on this issue. We will proceed with
some exploratory discussions with the Office of Naval Research for
inclusion of an off-campus VA specific rate for Stanford. In the
meantime, note how fitting it is that I write to you on this subject on
March 17! If I can provide any further information, please let me know.
Sincerely,
Geoffrey E. Grant
Associate Vice President for Research Administration |
