 |
|
 |
|
|
|
|||
I. GENERAL(Note: 2 CFR Part 220 replaces the OMB Circular A-21. This Part speaks to the purpose, scope, policy, and other issues relevant to cost principles. When determining costs applicable to grants, contracts, and other agreements with educational institutions, Federal program Directors and Fiscal Officers will refer to this title.) 2 CFR Part 220 defines Direct Costs as costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity; or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
These types of costs are consistently treated by Duke University as Direct Costs to sponsored projects. The CFR Part 200 further instructs universities to ensure that costs incurred for the same purpose ‘in like’ or similar circumstances are treated consistently as either Direct or Indirect costs. Additional information regarding this can also be found in GAP 200.320, Direct Costing on Sponsored Projects and GAP 200.330, Facilities and Administrative (Indirect) Costs on Sponsored Projects. Administrative and clerical expenses (for example, salaries of clerical & administrative personnel, office supplies, postage, local telephone costs, and memberships) should normally be treated as Facilities and Administrative (F&A) or Indirect Costs and not directly charged to sponsored projects. This guiding principle for handling administrative expenses is established, and clarified in 2 CFR Part 220, now A-21. 2 CFR Part 220 further provides that administrative expenses may be directly charged to sponsored agreements under certain circumstances. Universities may charge directly for these clerical salaries “when a major project or activity explicitly budgets for administrative or clerical services, and individuals involved can be specifically identified with the project or activity.” Non-salary administrative costs may be charged to a Federal award if these costs are utilized for a purpose, and in a manner that is “unlike” the consistent use of these items throughout the University. For example, a project funded to conduct a national survey may require significant purchases of paper and postage in order to meet its specific research goals. The paper and postage is being used specifically to conduct a research survey, and not as operational support for many activities. This is an example of an “unlike” circumstance . Duke University has established a formal process for reviewing and approving clerical and non-salary administrative costs to be charged to Federal awards.
II. CRITERIA FOR CHARGING ADMINISTRATIVE EXPENSES DIRECTLY TO A PROJECTA. Administrative/Clerical Salary Support Administrative/ clerical salary support is ordinarily treated as an F&A cost. It may be charged directly to sponsored projects only under certain circumstances.
If the administrative expense does not meet the three criteria for direct charging, the expense should not be a direct cost to the sponsored project, and should instead be charged to department or school activities/ accounts. To secure approval for this type of expense, departments should prepare the Direct Cost Exception Form I: Administrative and Clerical Expenses Salaries at the time of award. The form should provide sufficient justification for the expense, including a description of the project in sufficient lay terms to provide an educated reader with a basic understanding of the purpose and scope of the funded project. The form should be signed as indicated and sent to the appropriate pre-award office for further review and approval. Once approved, the Office of Sponsored Programs will establish the appropriate budget in the project’s WBSE as indication of an approved and allowable expense. B. Salary and Administrative Expenses Administrative non-salary support (e.g. office supplies, postage, local telephone costs, and memberships) is ordinarily treated as an F&A cost. Please note that these administrative costs must be planned, and used exclusively for a project’s technical scope of work. The project need not be a major project, as defined in section IV, for salary and administrative costs to be charged directly. They must however, meet the above criteria in order to be directly charged to the sponsored research. Direct charging of these costs may be accomplished through specific identification of the costs to the sponsored project or through recharge centers or specialized service facilities, as appropriate under the circumstances. For approval of these types of expenses, departments should prepare the Direct Cost Exception Form II: Non-Labor Direct Costs prior to charging the expense. The form should provide sufficient justification for each expense category. It should also include a description of the project, in sufficient lay terms to provide an educated reader with a basic understanding of the purpose and scope of the funded project, and the relationship of the expense to the project’s activities. The form should be signed as indicated, and sent to the appropriate pre-award office for further review and approval. Once approved, the Office of Sponsored Programs will establish the appropriate budget in the project’s WBSE as indication of an approved and allowable expense.
III. REBUDGETINGRecognizing that sponsored research is dynamic, unanticipated clerical and administrative non-salary costs may become necessary. In these circumstances, departments should complete the Request for Rebudgeting of Funds with specific attention to the CAS approvals embedded in the form. Complete the form as indicated, provide specific information regarding the need for the expense in terms of the purpose and scope of the project. Also provide a brief statement as to why these costs were not identified in the original budget submitted to the Federal sponsor. Once approved by the appropriate pre-award office and the Office of Sponsored Programs (OSP), OSP will establish the appropriate budget in the project’s WBSE as indication of an approved and allowable expense.
IV. MAJOR PROJECTSMajor projects are projects where direct charging of administrative expenses may be appropriate in that they require an extensive amount of administrative or clerical support that is significantly greater than the routine level of such services provided by academic departments. 2 CFR Part 220 (Exhibit C to Appendix A—Examples of “major project” Where Direct Charging of Administrative or Clerical Staff Salaries May Be Appropriate) provides examples of major projects, these examples are not exhaustive nor are they intended to imply that direct charging of administrative expenses would always be appropriate for the situations illustrated in the examples. Projects that could have the necessary characteristics to justify direct charging of administrative expenses include, but are not limited to the following:
Note: Research Costing Compliance monitors for appropriate documentation, internal controls and adequate justification. If the forms are inadequate or missing during the monitoring process, RCC will work with the appropriate management center to ensure that documentation is in place during the life of the project or at closeout. OSP will ensure that CAS expenses have been properly budgeted at the time of closeout and will write off any expense that is not appropriately justified and approved. (See GAP 200.180, Closeout of Sponsored Projects)
V. RESOURCESFor Pre-Award administration, contact either:
For Post-Award administration contact:
For additional information and guidance, please review a brief tutorial on CAS processes. Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.
|
Duke University
>>
Financial Services
>> General Accounting Procedures
|
|
||||||||||||||||||||||||||
| Financial Services Home | Sitemap | About This Site |
