Allowability of Costs
Allowability of Costs on Federally Sponsored Projects
A. Direct Costs:
The following types of costs should be directly charged to sponsored agreements when they can be specifically identified to the work performed under those agreements.
- Salaries, wages and fringe benefits: faculty, research associates, predoctoral and postdoctoral, technicians and lab assistants.
- Specialized equipment.
- Travel Costs.
- Supplies and Materials: chemicals, laboratory supplies, computer software, drugs, uniforms, photographic supplies, tools, and animals.
- Other Direct Costs: radioactive waste disposal, consulting Services, animal care, freight and express, patient care and subject costs.
Costs that are normally treated as indirect costs MAY be charged to Non-federally sponsored agreements if permitted by the sponsor’s policies/practices or are otherwise approved by the sponsor.
B. Indirect Costs:
The following costs are usually treated as indirect costs for sponsored projects and should not be charged directly to sponsored agreements. They may be treated as direct costs only under exceptional circumstances, see Section C
- Salaries of administrative and clerical staff
- Office supplies, especially those used in clerical or support offices where salary is not directly charged to sponsored projects and the administrative salaries do not meet the definition of unlike circumstance, or those used in faculty offices. Office supplies includes binders, folders, business cards, copy paper, envelopes, paperclips, pencils, pens, scissors, staplers, tape, message pads, accent makers, notebooks, etc.
- Furniture (including items needed in a laboratory).
- Toner cartridges and diskettes
- Basic local telephone services on campus. Includes phone installation, monthly line charges and Ethernet charges.
- Cellular phones, pagers and related service charges.
- General Purpose equipment such as desktop computers, printers, laptops, PDAs, electronic calendars, etc.
- Routine copying charges that cannot be identified with specific projects
- Memberships, journals and subscriptions.
- Library charges
C. Exceptional Circumstances:
- CLERICAL/ADMINISTRATIVE SALARIES (INCLUDING SECRETARIAL) Under the OMB Circular A-21 provisions, clerical, secretarial, and administrative salaries must be explicitly budgeted and justified in the budget narrative. Principal Investigators and their departments are responsible for demonstrating that the nature of the work performed under a research project demands clerical and administrative support beyond that routinely provided by departmental budgets.
- OMB has published an interpretation of the new A-21 language including some examples of proposals where direct charging the salaries of administrative or clerical staff may be appropriate:
- Large, complex programs, such as General Clinical Research Centers, Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
- Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting, such as epidemiological studies, clinical trials, and retrospective clinical records studies.
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
- Projects that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels, radio astronomy projects, and other research field sites that are remote from the campus.
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocol, IRB preparations and/or other project-specific regulatory protocols; and multiple project-related investigator coordination and communications.
- Clearly PIs should be particularly attentive to requests for clerical/administrative assistance. Identification of the individual, clear justification about the nature of the duties and their direct relationship to the sponsored work, and a reasonable level of effort commensurate with the scope of the project are very important. A statement that the PI directly supervises this individual may be helpful. Appropriate language might include:
- special manuscript preparation skills
- recruitment and appointment of project employees
- research institute projects: no university support for research
- clerical assistance: support for instructional activities is provided elsewhere.
Agency approval will be assumed if the salary of administrative or clerical staff is budgeted and not specifically denied in the notice of grant award or in related correspondence from the agency to the University.
2. TELECOMMUNICATIONS EXPENSE. Basic local telephone services on campus, include phone installation, monthly line charges and ethernet charges, cellular phones, pagers and Ethernet charges should be treated as F&A. Local phone services would be allowable as direct costs under a program requiring telephone surveys, or need of a hotline crisis line that is specifically required by a grant and contract.
3. POSTAGE. Normally treated as F&A costs. However, a particular project may have a special need for postage that is clearly different than normal, e.g. the mailing of survey questionnaires is required. As the objectives of the project constitute “unlike circumstances” compared to routine postage requirements, it would be appropriate to charge the project directly for the postage to mail the questionnaires in this case.
4. SUPPLIES. Items that are used in the course of multiple activities of project personnel are "office supplies," while those used exclusively in support of the project are considered "consumable supplies." Direct charge to object 64002 ( Consumable Supplies) only those items which:
are consumed completely in the course of the project;
can be demonstrated to be used only in the conduct of the project and are not used for other purposes.
Items such as lab notebooks, diskettes, transparencies, plotter pens, printer paper for research data and reports, pens, tablets, staples, file folders, binders, toner cartridges, printer toner, etc. that are used only for project purposes are justifiable. "Consumable supplies" also include laboratory supplies and materials. When such items are purchased to support the multiple activities of project personnel (e.g. data notebooks for grad students that may also be used as course notebooks), they may not be directly charged to Federal projects. Items that would likely be used for other purposes or not entirely consumed in the course of the project -- wall clocks, calendars, waste cans, paper punches, University stationery, staplers, and the like - should not be directly charged to Federal projects.
5. COPYING. Routine Copying charges that cannot be identified with specific projects should not be directly charged to Federal projects.