RSP 508–01: Charging Direct and Facilities & Administrative Costs to Sponsored Projects
Office of Management and Budget. OMB Circular A-21 (revised), Cost Principles for Educational Institutions
Office of Federal Procurement Policy, Cost Accounting Standards Board, Appendix A, Part 99005, Cost Accounting Standards for Educational Institutions
Office for Research and Sponsored Projects Administration (ORSPA)
Expenditure of funds under all sponsored agreements
Expenditure of funds from cost-sharing and program income accounts
It is the policy of the university to account for expenditures in a consistent manner. The consistent treatment of expenditures, as direct costs or as facilities & administrative (F&A) costs, ensures that sponsors do not pay twice for the same type of costs.
According to OMB Circular A-21, consistency means that costs incurred for the same purpose, in “like circumstances,” must be treated uniformly as either direct costs or as facilities & administrative costs. Certain types of costs (e.g., salaries of administrative and clerical staff, office supplies, postage, local telephone charges) are normally treated as facilities & administrative costs (indirect or overhead costs) and cannot be charged directly to sponsored projects unless “unlike circumstances” can be justified.
Facilities & administrative costs will be considered for direct charging in accordance with the guidelines of OMB Circular A-21.
The direct charging of administrative and clerical expenses may be approved under the following circumstances:
The following are examples, from OMB Circular A-21, of circumstances under which such expenses may be charged directly:
The direct charging of office supplies, postage and/or telecommunications costs, substantially beyond that normally provided by the responsible administrative unit, may be approved under the following circumstances:
|Note:||Sponsor approval of a budget does not in and of itself constitute approval of the specific line items. The sponsor assumes ASU compliance with OMB Circular A-21, ASU’s Cost Accounting Standards Board Disclosure Statement, ASU’s F&A rate proposal assumptions, and all other governing regulations. A cost that may be allowable at one institution as a direct charge may not be allowable at another institution because of the differences in the Disclosure Statement and the F&A rate proposal. Sponsors rely on grantees to apply the above governing regulations; thus it is the university’s responsibility to exercise due diligence on cost accounting matters.|
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