OSP is happy to announce the new F&A Cost Waiver Request DocuSign form! You may find this form on the OSP website under the Forms Page. Per UMBC policy IV-2.00.01, UMBC requires the application of its full and applicable federally negotiated F&A cost rate on ALL Sponsored Project proposals and awards.

UMBC may allow for the application of a rate lower than its full and applicable federally Negotiated Indirect Cost Rate Agreement (NICRA) rates under the following two (2) limited and special conditions:

1. Limit Imposed by Sponsoring Agency Policy. Some federal, state, and private sponsors impose an F&A cost rate that is below the federally negotiated rate. Similarly, many private foundations limit or exclude F&A as a matter of policy. In effect, they are requiring the recipient institution to agree to share in the cost of performing the proposed work, even though this is not stated formally as “cost UMBC Policy # UMBC IV-2.00.01 Page 2 of 4 sharing”. In all such cases, the decision to proceed with a proposal will depend on the non-monetary value of the Sponsored Project to the institution, traded off against the under-recovery of F&A costs that are incurred.

2. Sponsored Project proposals that are intended to get a new investigator started in a research area or help an established investigator begin working in a new field may call for a reduction or elimination of the F&A portion of the proposed cost. It may be in the institution’s best interests in these cases to preserve the direct cost expenditures and reduce the recovery of indirect costs. It is expected that such proposals will be limited in duration and scope and will promote future funding that will recover full F&A costs.

**Please note if the sponsor has a published written policy, an F&A cost waiver is not required, simply upload the policy to Kuali**

All requests will be reviewed on a case-by-case basis. Please ensure adequate documentation is provided to justify the request for a waiver. The waiver can be initiated by a PI’s business administrator or Shared Service Center (SSC). It is recommended that the Kuali proposal be started but not routed fully for signatures until after the F&A waiver has been reviewed and either approved or denied by OSP and ORCA. Please ensure the finalized waiver is than attached to the Kuali proposal for routing.

The current F&A Cost Waiver Request form that is required for manual routing for signatures will be active until August 1^st 2025. During this time OSP and ORCA will accept either the new DocuSign or the old form;  however, ONLY the DocuSign will be accepted after August 1^st.  If you have any questions, please feel free to email us at ospa@umbc.edu. 

Thank you,

OSP

As you may have already received an email or have otherwise heard, the U.S. National Science Foundation (NSF) issued a Dear Colleague Letter that stated Principal Investigators and co-PIs named on an NSF award made after 5/20/24 must certify on an annual basis in research.gov that they are not part of a Malign Foreign Talent Recruitment Program (MFTRP).  Individuals who are party to an MFTRP are not eligible to serve as senior/key personnel on an NSF proposal.  Furthermore, all federal grant funding agencies have similar provisions that prohibit key personnel from participation in an MFTRP.   

This new directive from NSF should have very little impact on the UMBC research community as UMBC implemented a question regarding MFTRPs into the Kuali COI disclosure process over a year ago.  This new NSF directive doesn't replace UMBC's policy on MFTRPs and yes, unfortunately it does create duplicative reporting requirements.  As the UMBC research community receives grants from multiple federal grant funding agencies, and each agency has slight variations on MFTRP prohibitions, we cannot rely exclusively on one federal agency to handle this responsibility on our behalf.  Therefore, the MFTRP attestation statement will remain a part of your annual COI disclosure requirements.  

MFTRPs, also sometimes referred to Foreign Talent Recruitment Programs (FTRPs), are not uniformly defined by various federal agencies and are considered unmanageable conflicts of interest.   MFTRPs are in essence clandestine research programs sponsored by foreign governments, oftentimes who are adversarial to the U.S. government, that fall outside of the scope of normal international collaborations and accepted practices.  These programs typically direct participants to not disclose their participation or to even take measures to actively conceal their involvement in the MFTRP from their institution as well as federal grant funding agencies, do not allow for open research publications and may ask participants to engage in activities that would be considered unethical by their institution or even illegal, such as violating U.S. export laws.  Should you ever have questions about an international collaboration that you are concerned about, please contact ORPC at researchintegrity@umbc.edu   or you can visit Domestic and International Affiliations and Collaborations – Division of Research & Creative Achievement – UMBC for more information. 

UPDATE: Below is the question as it appears in Research.gov that requires an answer:

* Required
In accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1.e(ii) C, all senior/key personnel who are party to a malign foreign talent recruitment program are not eligible to serve on an NSF award made on or after May 20th, 2024. On an annual basis, Pls and co-Pls are required to certify that they are not party to a malign foreign talent recruitment program (MFTRP). For your reference, the definition of an MFTRP can be found here C.

* In your role as a PI or co-Pl, are you party to a malign foreign talent recruitment program? 

No

Yes

As you may have already received an email or have otherwise heard, the U.S. National Science Foundation (NSF) issued a Dear Colleague Letter that stated Principal Investigators and co-PIs named on an NSF award made after 5/20/24 must certify on an annual basis in research.gov that they are not part of a Malign Foreign Talent Recruitment Program (MFTRP).  Individuals who are party to an MFTRP are not eligible to serve as senior/key personnel on an NSF proposal.  Furthermore, all federal grant funding agencies have similar provisions that prohibit key personnel from participation in an MFTRP.    As of the date of this notification (6/6/2025), UMBC has not received nor had an opportunity to review the actual question that is being asked by NSF in this disclosure requirement.

This new directive from NSF should have very little impact on the UMBC research community as UMBC implemented a question regarding MFTRPs into the Kuali COI disclosure process over a year ago.  This new NSF directive doesn't replace UMBC's policy on MFTRPs and yes, unfortunately it does create duplicative reporting requirements.  As the UMBC research community receives grants from multiple federal grant funding agencies, and each agency has slight variations on MFTRP prohibitions, we cannot rely exclusively on one federal agency to handle this responsibility on our behalf.  Therefore, the MFTRP attestation statement will remain a part of your annual COI disclosure requirements.  

MFTRPs, also sometimes referred to Foreign Talent Recruitment Programs (FTRPs), are not uniformly defined by various federal agencies and are considered unmanageable conflicts of interest.   MFTRPs are in essence clandestine research programs sponsored by foreign governments, oftentimes who are adversarial to the U.S. government, that fall outside of the scope of normal international collaborations and accepted practices.  These programs typically direct participants to not disclose their participation or to even take measures to actively conceal their involvement in the MFTRP from their institution as well as federal grant funding agencies, do not allow for open research publications and may ask participants to engage in activities that would be considered unethical by their institution or even illegal, such as violating U.S. export laws.  Should you ever have questions about an international collaboration that you are concerned about, please contact ORPC at researchintegrity@umbc.edu   or you can visit Domestic and International Affiliations and Collaborations – Division of Research & Creative Achievement – UMBC for more information.  

UMBC Research Administrator's Community:

Are you interested in networking, sharing resources, and learning best practices within UMBC's Research Administrator's Community?

We are looking for both Mentors and Mentees who would like to benefit from this program.

Wednesday, June 4 is the deadline to sign-up for our FY2026 Research Administrator's Mentoring Program.

We welcome all questions and comments about the program and encourage you to speak with your supervisor about interest and time commitments.