{"id":723,"date":"2018-05-01T08:25:09","date_gmt":"2018-05-01T08:25:09","guid":{"rendered":"https:\/\/az.research.umich.edu\/medschool\/document\/indirect-cost-waivers-federal-patient-pass-through-costs\/"},"modified":"2026-01-07T17:59:21","modified_gmt":"2026-01-07T22:59:21","slug":"indirect-cost-waivers-federal-patient-pass-through-costs","status":"publish","type":"document","link":"https:\/\/az.research.umich.edu\/medschool\/policies\/indirect-cost-waivers-federal-patient-pass-through-costs\/","title":{"rendered":"Indirect Cost Waivers on Federal Patient Pass-Through Costs"},"template":"","categories":[71],"tags":[],"content-type":[72],"topic":[73],"update-type":[],"class_list":["post-723","document","type-document","status-publish","hentry","category-grant-services-analysis","content-type-policies","topic-indirect-cost"],"acf":{"use_legacy_editor":true,"updated_date":"2018-05-01 08:25:00","update_notice":false,"author":"Grant Services & Analysis","summary":"This policy describes the process and conditions for Medical School units seeking a reduction of indirect costs on pass-through expenses related to clinical trial patient payments on federal projects. Please review the School\u2019s companion policy on Indirect Cost Waivers for more information on indirect costs and the impact of reductions on the School.","button_links":null,"related_content":"","legacy_path":"indirect-cost-waivers-federal-patient-pass-through-costs","legacy_node_id":246,"legacy_related_nids":"","legacy_content_section":[{"legacy_section_type":"heading","legacy_heading":"Overview","legacy_subheading":"","legacy_section_text":"","legacy_media_position":"","legacy_media_file":"","legacy_media_url":"","legacy_glossary_term":"","legacy_glossary_nids":"","legacy_resource":"","legacy_resource_nids":"","legacy_buttons":null},{"legacy_section_type":"text_area","legacy_heading":"","legacy_subheading":"","legacy_section_text":"As the Medical School strives to advance groundbreaking clinical and translational research<\/a>, we recognize the challenge this type of research brings.\u00a0We have heard concerns from faculty that patient pass-through costs burdened with the full on-campus research indirect cost rate have created a financial challenge on federally funded, multi-site clinical trials<\/a>. These are situations where funds are provided to U-M with the purpose of sending out per patient reimbursements to various other sites<\/a> (through a contracted service or Hybrid Purchase Order mechanism).\r\n\r\nHaving researched the issue, we found that often federal sponsors<\/a>\u00a0allowed for full indirect cost recovery on per patient pass through costs consistent with our negotiated rate agreement, but had instituted a cap on the total funds available, making it nearly impossible to meet the work requirements of the announcement and still recover full indirects on the pass through costs.\r\n\r\nWe do recognize that there remains investment of university resources used to issue checks, establish contracts, and process official agreements, as well as unit overhead costs related to the post-award support of the project. Finally, our negotiated rates on campus are an average rate across all activities, so any change to lower recovery on this activity does depress the cumulative recovery across all projects.\r\n\r\nAfter review, the Medical School is willing to use a waiver allowing indirects to be recovered only on the current MTDC amount site, for this subset of activity. This waiver will only be allowed when agreed to by the administrative home department of the project.","legacy_media_position":"","legacy_media_file":"","legacy_media_url":"","legacy_glossary_term":"","legacy_glossary_nids":"","legacy_resource":"","legacy_resource_nids":"","legacy_buttons":null},{"legacy_section_type":"heading","legacy_heading":"Definition of Qualified Activity","legacy_subheading":"","legacy_section_text":"","legacy_media_position":"","legacy_media_file":"","legacy_media_url":"","legacy_glossary_term":"","legacy_glossary_nids":"","legacy_resource":"","legacy_resource_nids":"","legacy_buttons":null},{"legacy_section_type":"text_area","legacy_heading":"","legacy_subheading":"","legacy_section_text":"Only federally funded, multi-site<\/a> projects with identified and approved<\/a> pass through costs are eligible<\/a>. Qualified activity will be identified as capitated (or per patient) payments to sites enrolling<\/a> patients. The mechanism used by the Office of Contract Administration (OCA) to establish the agreements will likely be that of a Hybrid Purchase Order.\r\n\r\nThis policy will not apply to industry sponsored, multi-site projects. If you have questions regarding the applicability of this policy to non-federally sponsored projects please contact\u00a0msgrants@umich.edu<\/a>. If you are seeking a variation of this waiver, please contact\u00a0ummsresearch@umich.edu<\/a>.","legacy_media_position":"","legacy_media_file":"","legacy_media_url":"","legacy_glossary_term":"","legacy_glossary_nids":"","legacy_resource":"","legacy_resource_nids":"","legacy_buttons":null},{"legacy_section_type":"heading","legacy_heading":"Process","legacy_subheading":"","legacy_section_text":"","legacy_media_position":"","legacy_media_file":"","legacy_media_url":"","legacy_glossary_term":"","legacy_glossary_nids":"","legacy_resource":"","legacy_resource_nids":"","legacy_buttons":null},{"legacy_section_type":"text_area","legacy_heading":"","legacy_subheading":"","legacy_section_text":"No prior-approval or agreement to the waiver is necessary if the conditions below are met. A project will be approved<\/a> by the Medical School for use if:\r\n