Cost Accounting Standards

General

  • A-21 recognizes that indirect items such as clerical support, office supplies, telephone, space, etc. are needed to support any funded activity. Because it is difficult to accurately cost out these items on a project by project basis, the federal government choose to reimburse the institution through indirect cost. A justification which simply explains that a secretary will be working on the project is not sufficient. It is a "given" and is the reason we receive indirect cost.
     
  • Review the Special Purpose situations in the Costing Policy often. Any justification should relate to a Special Purpose. For example, how do the needs of a training grant differ from a research grant?
     
  • Review costs in light of the actual project work. A brief description of the work provided to the Research Administrator by the PI will facilitate meaningful review and feedback.

Following are points to consider and examples of adequate justifications for several items of cost:

Clerical/Support Staff

Questions to consider:

  1. What will this individual be doing that is different or in addition to his/her normal duties?
  2. What is unique about the responsibilities on the project? And, how does this tie in to scientific/programmatic objectives of the project?
  3. Is the position specific to the project and will not exist if the project is not funded?

More isn’t necessarily different. However, it can be different if there is a large order of magnitude, such as supporting a national conference or a "large, complex project."

  • Residency Training Grant:

            Example 1:

Jane Doe, Administrative Assistant. This cost is normally treated as an indirect cost at the University of Kentucky. However, due to the requirements of this project, university policy allows this cost to be requested and justified as a direct cost. The proposed project involves development, implementation and evaluation of eight workshops attended by on-site and off-site trainees with approximately 40 standardized patients. Ms. Doe will assist in the preparation of Student Guides and Instructor Reference for use by the trainees during their residency. Ms. Doe will be solely responsible for coordinating and scheduling the training workshops for on-site and off-site attendees. She will coordinate and schedule the standardized patients for the workshop. At the end of the workshops, it will be Ms. Doe’s responsibility to compile the student evaluations into a usable format for reporting results and for use in future workshops. 50% of her time will be devoted to this project.

Example 2:

Training Grant/Rural Outreach Proposal

Ms. G is the departmental Accounts Manager. The position is typically treated as an indirect cost at the University. However, due to the large and complex outreach component of the proposed project, University policy allows the 20% effort being requested for Ms. G to be requested and justified as a direct cost. Ms. G will assist the Principal Investigator in monitoring the invoices and processing payment documents for the 30 off-campus sites. She will arrange and coordinate the quarterly meetings held at the University for the off-campus site subcontractors.

  • Large Complex Project (Program Project):

Larry Jones, Administrative Assistant: This cost is normally treated as an indirect cost at the University of Kentucky. However, due to the nature of this project, university policy allows this cost to be requested and justified as a direct cost. This Program Project is large and complex, containing ten (10) separate components and additional supplemental funding. Further, the Program Project also entails multiple subcontractual agreements, which require extensive monitoring and liaison with the recipient institutions. Mr. Jones will be responsible for processing all payment documents involving all of the Program Project accounts. He will monitor and reconcile all fiscal accounts and will communicate regularly with Core and individual Project Leaders regarding the fiscal activity of the grant. He will be responsible for preparing a monthly financial report for each Core, Project and Pilot Program Leader. Further, he will develop overview reports of the financial activity on all projects within the Program for the Director, Dr. Smith. Mr. Jones will devote 80% of his effort to this Program Project

  • Conference Grant:

A Conference Manager (25% FTE) and a Staff Assistant (50% FTE) are being requested. These positions are typically treated as indirect positions at the University. However, given the requirements of this proposal that involve making travel and meeting arrangements for 150-200 state and district participants, the effort related to these positions is being requested and justified as a direct cost.

The Conference Manager will provide direction for organizing statewide and district conferences, agenda development, identifying key speakers and assisting with evaluation activities.

The Staff Assistant will be responsible for conference planning; identifying facilities; assisting in negotiating contracts with facilities; contracting with speakers; developing printed materials; acting as a liaison with the media and for all follow-up activities. The Assistant will also oversee the registration activities and data management component of conference activities.


Computers

Computing hardware is normally an indirect cost because computers are used in support of a variety of activities. However, in accordance with university costing policy computers may be charged to a sponsored agreement when all of the following criteria are met. The item must:

  • Be specifically identified with the project;
  • Be required to fulfill the scientific objects;
  • Have a preponderance of use (75% or greater) on the project;
  • Be specifically listed in the proposal budget and be awarded
     
  • Laboratory Based Research Project

A desktop computer (Dell, Optiplex 5200 GXMT) is requested to support the extensive cloning experiments and plasmid constructions described in this proposal. This cost is normally treated as indirect at the University of Kentucky. However, due to the requirements of this project, University policy allows this cost to be requested and justified as a direct cost. This computer is essential to fulfill the Specific Objectives of the proposal, including the construction of the human/rabbit chimeras, the construction of the multicistronic plasmids, and the design of oligonucleotide primers for polymerase chain amplification. The computer will be in heavy use for these purposes, and be used almost exclusively (80%) for the scientific aims of this proposal, with the remainder of the use for other scientific purposes. The software needed to design the plasmids, chimeric proteins, and oligonucleotide Primers (Lasergene, DNAStar, Inc.) will also be purchased on this grant.

  • Laptop Computer for Research Project with Off-site Data Collection

$3,000 is requested for a laptop computer. This cost is normally treated as indirect at the University of Kentucky; however, due to the requirements of this project, university policy allows this cost to be requested and justified as a direct cost item. The computer will be almost exclusively dedicated to the accomplishment of the specific aims of this project as described in the research plan (>80%); Specific aims 1 and 2 involve collection of clinical data from primates at three off-campus test sites. The laptop will enable the researchers to enter data from primates at three off-campus sites. The laptop will enable the researchers to enter the data as it is received and review the entered data while still at the site. The data can then be transferred from the test sites directly to the university for analysis. On-site computer entry facilitates quality control and removes the possibility of human error which could occur while transferring data from a hand written record to a computerized data base.

University of Kentucky | UK Research
Updated March 9, 2012 | Questions/Corrections to Sean Scott