Federal research funds are generally provided as cost reimbursable awards, i.e., the university bills the sponsor for costs incurred and is reimbursed for allowable costs. It is the goal of the university to maximize research award reimbursement by ensuring that costs incurred follow sponsor policy. The primary source of guidance on all aspects of federal sponsored awards is Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly known as 2 CFR 200 or Uniform Guidance. The Cost Principles, which govern allowable costs are included in Subpart E of the Uniform Guidance.
Some federal awards may have restrictions more specific than the Uniform Guidance, such as contracts subject to Cost Accounting Standards (CAS). Such restrictions are noted in the Award Overview tab in the PI Portal. Non-federal sponsors may also have specific restriction that will be noted in the PI Portal. If a sponsor does not have spending guidance, the university’s purchasing policy applies.
In order to be reimbursable by a federal sponsor, a cost must be
- allowable, i.e., be necessary and reasonable for the performance of the award activities
- reasonable, i.e., not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost
- allocable, i.e., be charged or assigned to the award in accordance with the relative benefits received.
Direct cost allocation
Goods and services purchased under a sponsored award may often benefit more than one award. Such costs must be allocated to sponsored awards in proportion to the actual benefit received by the awards. If it is impractical to determine how much of the goods or services are actually used for each award, an allocation methodology must be developed and documented that reasonably estimates the actual benefit to each award. Costs are then distributed to each benefiting sponsored award using the allocation methodology. For on-going allocations, the methodology should be reviewed and documented no less often than annually.
Classification of Costs
Direct Costs are costs that can be identified specifically with a particular sponsored award, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
Facilities and Administrative Costs (F&A Costs)
F&A (Facilities and Administrative) costs (formerly known as Indirect or Overhead Costs) are costs that support the sponsored project enterprise but that cannot be identified readily and specifically with a particular sponsored award. Facilities costs include building and equipment depreciation and operation and maintenance expenses. Administrative costs include general and administrative expenses; library expenses; and student administration and services. F&A costs are reimbursed in accordance with the university’s current F&A rate agreement.
The total cost of a federal award is the sum of the allowable direct cost and the allocable F&A costs.
Costs Generally Considered Allowable as Direct Cost
The following types of costs should be directly charged to federal sponsored awards if they can be specifically identified with the work performed under those awards:
- animal purchase and care
- alterations and renovations when approved as part of the proposal
- computing devices that are essential for, and allocable to the federal award
- consulting services
- delivery charges for equipment and supplies
- equipment necessary for the federal award
- graduate student tuition
- itemized local and long-distance telephone costs
- patient care and subject costs
- publication costs
- salaries, wages and fringe benefits for personnel working on the award
- supplies and materials
- travel costs
Costs Normally Treated as Indirect Costs (F&A)
The following costs are usually treated as F&A costs for federal sponsored awards:
- administrative and clerical salaries
- audit costs
- books, institution’s subscriptions for journals and periodicals
- depreciation or use allowances
- general purpose equipment: non-research equipment, which may be used for general office purposes such as computers, printers, fax machines, copy machines, and office furniture
- hazardous waste removal
- legal costs
- local travel costs (meals, parking)
- office supplies
- postage including U.S. Postal Service, Federal Express, UPS
- proposal preparation costs
- routine copying charges that cannot be identified with specific awards
- telecommunications - local telephone service, including phone equipment such as telephones, cell phones, pagers, fax machines, and line charge
As noted above, Uniform Guidance applies to federal sponsored awards and federal flow-through sponsored awards. Costs normally charged as F&A may be charged directly to non-federal agreements if not prohibited by sponsor or university policy.
Costs Generally Classified as Unallowable
The following costs are generally not allowable as either direct or as F&A costs for federal sponsored awards:
- alcoholic beverages
- bad debts
- contingency funds
- entertainment costs
- fines and penalties
- fundraising costs
- salaries and wages for time spent on proposal development/writing
- termination or suspension costs
Additional information on specific costs is provided in the Uniform Guidance section § 200.420.
Charging to Direct Costs What is Usually F&A
Generally, for allowable costs to be charged to federal awards, they must be treated consistently i.e., costs incurred for the same purpose, in like circumstances, must be treated uniformly as either direct costs or F&A costs. However, under certain circumstances costs that would normally be charged as F&A may be charged as direct costs. The two criteria that allow F&A costs to be reclassified as direct cost are:
- the cost must be incurred under “unlike circumstances” rather than the normal or typical circumstances that dictate that a cost be classified as an F&A cost.
- the cost must be specifically associated with the subject award with a high degree of accuracy.
Administrative/Clerical Salaries are generally unallowable as direct charges. However, direct charging may be appropriate if:
- administrative or clerical services are integral to a project or activity
- individuals involved can be specifically identified with the project or activity
- such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency, and
- the costs are not also recovered as indirect costs
Examples of when direct charging may be appropriate include:
- large complex projects such as NIH Program Projects and Center awards, NSF Research Center awards and other projects that require coordinating the activities of investigators from a number of different departments and, possibly, different institutions
- projects such as conference grants that require making travel and meeting arrangements for large numbers of participants
In each case, the administrative person should be named in the proposal budget and a clear justification provided for why the increased level of administrative support is required by the project.
One of a principal investigator’s responsibilities is to monitor project expenditures and commitments to ensure that they do not exceed the project budget. To support this activity, the Office of Sponsored Programs provides current project financial data through the PI Portal.
While a principal investigator may designate other persons as “authorized signers” for the project, he or she retains responsibility for ensuring that the project is conducted within the authorized budget. If a project ends with an overexpenditure, the Office of Sponsored Programs transfers the direct cost portion of the overexpenditure to the cost centers listed in the expenditure allocation section of the PA-005.