A. Administrative vs. Technical Expense - General
B. Major Projects
C. Distribution of Expense Between Two or More Projects
D. Administrative/Clerical Salaries and Wages
F. Reduced Overhead Rates as Justification for Administrative Expense
G. Agency Approval Alone Is Not Ample Justification for Administrative Expense
H. Documentation Requirements
I. Delegation of Authority
J. Specifically Disallowed Costs
A1. My research group would like to rent a water cooler and charge our NSF grant as the fund source. My research team occupies about 2,000 ASF in one campus building and the nearest building water fountain is one floor down. The cost was not budgeted for or justified in the NSF proposal. Can we charge the water cooler as a direct cost to the NSF award?
Probably not. Since the cost does not appear to be required for the technical scope of the work, it will need to meet the allowability tests in A-21 for administrative costs. The cost appears to be routine in nature and does not specifically meet any of the A-21 criteria for a "major project". Thus, the expense would not be allowable as a direct cost to the sponsored award.
A2. I would like to rent a water cooler to be used by human subjects who participate in the conduct of my NIH project and must remain on site, without leaving, for up to 3 hours at a time. The cost has not been budgeted for or justified in the original NIH proposal. No other projects use the space or the water cooler. Can I charge this cost to my NIH award?
Yes, with documentation. The water cooler appears to be necessary for the technical conduct of the NIH project and could therefore be allowed as a direct cost to the project. Since the cost, however, was not originally proposed and approved, it could only be charged to the NIH award if rebudgeting authority exists for the award and the PI provides written justification for the technical expense.
A3. What if the water cooler purchase in the above question is used by my researchers and other visitors in addition to the human subjects? Would this change its allowability?
No. The use of the water cooler by others in the research group would not change the allowability of the cost so long as the use remains incidental to the technical purpose. Once the use of the water cooler ceases to further the technical scope of work, it becomes administrative in nature and would need to meet the tests of allowability for administrative costs outlined in campus policy.
A4. A sample that will expire in 36 hours requires analysis by a third party. Can I use an express delivery service to transport the sample and charge the transportation costs my ONR grant that is sponsoring the work?
Yes. Because of the time sensitive nature of the sample and the purpose for which it was incurred, the advancement of the project's technical scope, this normally administrative cost is now considered a technical cost and could be directly charged to the ONR award. The cost must also meet the other tests for direct-charging (it can be specifically identified to the ONR award, is reasonable and has not been specifically disallowed).
A5. What if the same research group needs to use an express mail service to deliver an interim technical report due to the agency in 2 days and delivery by the due date cannot be guaranteed with standard mail?
Postage and mailing costs are normally treated as indirect costs, but could be justified as a direct cost to sponsored awards if they are necessary for the technical scope of the work and are reasonable and allocable to the sponsored award. In this example, the cost has been incurred for the technical scope of the project and identifiable to the project and could therefore be charged directly to a sponsored award.In hac habitasse platea dictumst. Suspendisse dictum, velit vel vehicula gravida, turpis nulla dignissim nibh, a tristique enim dui vestibulum enim. Duis cursus euismod diam vitae gravida. Etiam a purus lorem.
A6. Can I charge to my sponsored project the cost of photocopying research papers and making transparencies used to provide background for the research project and for the presentation of original research results at a professional technical meeting?
Yes, provided the costs can be identified to and benefit the project charged. Since these costs pertain to the project's technical scope of work (dissemination of technical information is a requirement of sponsored agreements), these normally administrative expenses would be considered technical and could be directly charged to the sponsored award as long as they can be specially identified to and benefit the project.
A7. I would like to charge annual membership dues to a professional association to my NSF award. The membership entitles me to receive a copy of an internationally recognized periodical and also allows me a discount on registration fees for several international conferences in my field of study. Is this allowable?
Maybe. Memberships that are required for attendance at professional technical conferences can be directly charged to federal sponsors when the costs have been specifically budgeted for and justified in the grant proposal and not specifically disallowed by the granting agency. Because they are of a general benefit to research and academic endeavors and cannot be specifically assigned to benefit individual awards, memberships are normally considered indirect costs. Thus, the costs would need to be carefully justified and a relationship established between cost incurred and benefit received.
A8. What if I wanted to charge the membership dues to a non-federal sponsor?
Membership dues to a non-federal award are allowable provided the expense meets the tests of reasonableness, allowability and allocability. If the cost can be justified as necessary for the conduct of the award and is not specifically disallowed by the sponsor, it could be charged directly to a non-federal sponsor.
A9. As a faculty member, my department provides me with an office phone and pays for the monthly line fees and local calls, but does not provide any financial support for communications costs beyond that. I need three additional phones in my laboratory for my laboratory staff to communicate with other research teams, vendors etc., and as a safety precaution (we work long hours, late into the night). I have 2 federal grants and no other funding. I have asked to charge the monthly line fees, local calls and long distance calls for the three additional laboratory phones to my federal awards. My Department Manager tells me I cannot do this. Where am I supposed to put these costs if I cannot put them on the grants?
OMB Circular A-21 states local telephone costs and monthly line charges shall normally be treated as F&A costs. Thus, charging federal awards directly for costs normally considered indirect is problematic. If the PI has proposed and justified the costs as necessary to the technical conduct of the awards (or has rebudgeted for the costs under a local rebudgeting authority), and they have been approved by the sponsor, the costs can be placed on the federal award. Otherwise, they will be considered general support costs not specifically identifiable to particular awards, and alternate funding must be identified. In general, the federal government feels that telephone costs (other than long distance calls) are difficult to allocate with a high degree of accuracy to individual sponsored awards, thus an appropriate share of costs to awards cannot be made and a cost-benefit relationship cannot be established. Long distance calls, however, can be specifically identified to an activity and are therefore allowable provided they meet all the other tests of allowability.