The University of California, San Francisco (UCSF) has developed charging practice guidelines for sponsored projects in accordance with the Uniform Guidance and associated Cost Accounting Standards (CAS). Federal regulations mandate that universities establish consistent practices for defining and charging costs either directly or indirectly. 2 CFR Chapter I and Chapter II Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards sets forth the principles for determining the costs – direct vs. facilities & administrative (F&A), allowable vs. unallowable, etc. – applicable to federally sponsored projects and acceptable allocation methodologies.
As a recipient of federal awards, UCSF is required to periodically prepare F&A Cost Rate Proposals that comply with the guidelines set forth in Uniform Guidance Sections 200.414 through 200.419. In addition, UCSF is required to file a CAS Disclosure Statement (DS-2 - §200.419 Cost accounting standards and disclosure statement) identifying accounting practices, policies, and procedures for assigning costs to federally sponsored programs, and to attest to the consistent treatment of those practices.
It is the responsibility of principal investigators, department heads and administrators to understand and comply with this guidance in order to prevent disallowance of costs by the federal government. The actual agreements may incorporate additional project specific requirements.
The allowability of a particular charge to a particular Award-Project-DeptID-Function chart string always depends on specific facts, circumstances, terms, conditions, restrictions, and policies in effect at the time of the charge. Therefore, this document is intended to provide general guidelines for charging. More detailed information is contained in Appendix A, Unallowable Costs and the Frequently Asked Questions (FAQ). Also see these related documents:
II. DEFINITION OF COSTS
- Direct Costs are those costs that can be identified specifically with a particular sponsored project or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
- Refer to Uniform Guidance, 200.405 and 200.413 for additional information
- Facilities & Administrative (F&A) Costs (also referred to as Indirect Costs) are those costs that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project.
- Refer to Uniform Guidance 200.414 for additional information
- Unallowable Costs and Activities are costs and activities that cannot be directly charged to a federal contract or grant, nor can they be included in F&A rate calculations.
- Refer to Uniform Guidance sections 200.420 thru 200.475 for additional information
III. PRINCIPLES FOR CHARGING COSTS TO SPONSORED PROJECTS
In order for an expense to be considered appropriate as a direct cost the charge must be:
- Allowable – The cost must be allowable per the terms and conditions of the sponsored award, under applicable sponsor regulations, Uniform Guidance, 200.403, and University policies.
- Reasonable– The cost may be considered reasonable if the nature of the goods or services acquired, and the amount involved reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. Key factors in determining reasonableness are defined in Uniform Guidance, 200.404.
- Allocable – The cost must benefit the project and be directly attributable to the project or activity being performed. The cost can only be assigned and allocated to the project(s) based on that portion of the expense that represents the direct benefit to the project. In order to ensure allocable standards are met refer to Uniform Guidance, 200.405.
- Consistently treated – Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or F&A costs in order to avoid possible double charging of Federal awards. Refer to Uniform Guidance, 200.412, 200.413 and 200.414 for additional information.
IV. GUIDELINES FOR DIRECT CHARGING ADMINISTRATIVE COST TO FEDERAL PROJECTS
A.Treatment of Administrative Salaries and Benefits on Extramural Funds
In accordance with Uniform Guidance 200.413 the salaries of administrative and clerical staff should normally be treated as F&A (indirect) costs. The following departmental activities are considered routine administrative and clerical activities. As such, these costs are generally, unless justification is provided, not to be charged as a direct cost:
- General departmental administration
- Contracts and grants administration*
- Personnel activities/Payroll/Human Resources
- Accounting and budgeting activities
- Financial monitoring
- Processing vouchers and payments
- Administrative data entry
- Newsletter/brochure preparation
- Processing and tracking routine purchase orders
- Maintaining departmental databases
- Departmental Reception Activities
*Note: “Contracts and grants administration" in the above list includes the development of grant or contract proposals and associated activities such as word-processing, copying, mailing, and electronic proposal submission.
2.Non-Standard Treatment of Administrative Salaries and Benefits
Under certain circumstances the administrative salaries and benefits may be charged directly to a federal project. Per Uniform Guidance, Cost Principles 200.413 the following conditions must be met:
- Administrative or clerical services are integral* to a project or activity.
- Individuals involved can be specifically identified with the project or activity.
- Such costs are explicitly included in the budget or have prior written approval of the Federal awarding agency.
- These costs cannot also be recovered as indirect costs.
* UCSF has determined integral to mean the following:
- Personnel costs must be essential, vital, or fundamental to the performance of the award or activity as documented in the award proposal or scope amendment.
- Generally administrative and clerical support as individual annual effort must not be less than 10% per year as documented in their effort report.
- In instances where an individual is on 3 or more awards and has substantial cumulative annual effort charged to federal sources, budgets must be evaluated for appropriateness with university and federal guidelines.
3. Qualifying Questions for Preparing Budget Justifications for Non-Standard Treatment of Administrative Salaries
When justifying administrative/clerical salaries (or before charging such expenses to a sponsored project), it is helpful to address the issues listed below by describing how the administrative role is essential or vital to the project
- Are the administrative support needs of this project significantly greater than the routine level of administrative support provided for all projects? If yes, why? Also, describe how the administrative support activities of the administrative/clerical personnel working on the project are necessary for the successful performance of the project.
- Does a job title or payroll classification imply that an individual’s work is administrative in nature? If yes, but the employee will not be engaged in administrative work on a sponsored project, describe the specific non-administrative work the individual will be performing, as well as how such work is necessary for the technical performance of the project.
- Can the proposed administrative/clerical support costs be easily and accurately allocated to the project? If yes, explain how this will be done. For example, an administrator working full-time for a project can be allocated easily and accurately to the project. However, if that person works on multiple projects, it may be difficult to accurately document the relative benefit of the administrator’s salary (effort) to any specific project. The more projects a person works on, the more difficult it is to accurately and easily document the relative benefit to each project.
B.Treatment of Non-Salary Administrative Expenses
In accordance with Uniform Guidance the following examples of non-salary expenses are normally to be treated as F&A costs and should not be budgeted in proposals or charged to sponsored projects as direct expenses as the costs are incurred for a common or joint purpose benefitting more than one objective and/or sponsored project.
Examples of these indirect costs include:
- Basic telephone line and equipment charges and local telephone services
- Routine postage costs and mail stop charges
- Routine reproduction
- Ordinary repairs and maintenance for state-supported space in UCSF-owned buildings or at the SFGH site
- Office supplies used for administrative activities
- Employee ID badges
- Fingerprinting (in some cases)
- Memberships in technical and professional organizations
- Subscriptions to professional or technical periodicals that may already be available through the campus library.
- Equipment depreciation
2.Non Standard Treatment of Non-Salary Administrative Expenses
In accordance with Uniform Guidance, non-salary administrative expenses may be budgeted and charged as a direct cost to sponsored projects if the cost is vital to the performance of the sponsored project. In these special circumstances the administering departmental unit must maintain documentation and justification that explains and supports the following conditions
- The expense can be specifically identified, with relative ease and high degree of accuracy with the sponsored project
- The sponsored project must require non-salary administrative expenses that are significantly greater than the routine level of support
To ensure reasonableness and allocability of non-salary administrative expenses being charged as direct costs it may be necessary for the administering departmental unit to seek prior written approval from the sponsor. Confer with Appendix III to Part 200 B.6 Departmental Administration Expenses for additional information and a listing of cost items for which prior approval may be required.
- Qualifying Questions for Preparing Budget Justifications for Non-Standard Treatment of Non-Salary Administrative Expense
When justifying non-salary administrative expenses (or before charging such expenses to a sponsored project), it is helpful to address the following issues:
- Are the non-salary administrative needs of this project significantly greater than the routine level of non-salary administrative support provided for all projects? If yes, why? Also, describe why it is necessary to incur the non-salary administrative expenses for the successful performance of the project.
- Can the proposed non-salary administrative expenses be easily and accurately allocated to the project? If yes, explain how this will be done.
V. UNALLOWABLE CATEGORY OF EXPENSES
Unallowable expenditures are costs for activities that may not be directly charged to a federal contract or grant, and often non-federal grants and contracts, and which also must be excluded from federal F&A rate calculations. Unallowable expenditures are excluded from F&A rate calculations through the use of appropriate unallowable Accounts (Accounts - see Appendix A). These Accounts must be used to charge unallowable expenditures, regardless of the Award-Project charged.
VI. GUIDELINES FOR DIRECT-CHARGING NON-FEDERAL PROJECTS
Under UCSF policy, it is permissible to charge normal department administration costs to any non-federal sponsored project fund that benefits from the costs and that are allowed per the sponsor terms and conditions. When this occurs, such costs will then be treated as direct costs of the sponsored project charged, not as F&A costs. Refer to policy 300-19 Expenditures of Sponsored Research Funds for additional information.
VII. CHARGING MATERNITY LEAVE, EMPLOYEE SEPARATION ADMINISTRATIVE COST, AND AWARD TERMINATION, TO SPONSORED AWARDS
Guidance regarding the allowability of all costs, including leave, pensions and unemployment benefits, is based on Uniform Guidance 200.431, sponsor award terms and conditions, and UCSF policy.
In general, UCSF maternity policy for birth and adoptive mothers begins two weeks before birth and ends six weeks after the birth (eight weeks for caesarian section). The maternity leave pay is under the University's Pregnancy Disability Plan. The 8 weeks of short-term disability is a fringe benefit and is funded centrally; it cannot be charged to sponsored awards and is not considered paid time off. However, depending on the type of award it may be allowable as part of the fringe benefit or indirect cost line item budget. In these instances the supporting documentation from the sponsor will be required.
Under specific circumstances employee separation, administrative expense, and award termination expense, can be charged to Federal Awards.
See Appendix D for references and additional information.
VIII. EFFORT REPORTING
Effort is the portion of time spent on a given professional activity expressed as a percentage of the total professional activity for which an individual is employed by the University of California. Total professional activity includes research, teaching, patient care, administrative and other University appointed activities.
Uniform Guidance requires an effort certification system that:
- Is supported by a system of internal controls which reasonably assures that the charges are accurate, allowable and properly allocated
- Reasonably reflects the total activity of the employee (100% effort)
- Confirms effort expended after-the-fact in compliance with the established accounting policies and practices of the University
- Requires certification to be incorporated into the institutions official records
UCSF utilizes the Effort Reporting System (ERS) to report on and certify the effort for each employee who works on a federally sponsored agreement. Per academic policy APM-110, faculty is responsible for (1) teaching, (2) research and other creative work, (3) other professional activity, and (4) University and public service. Some sponsor agencies, such as agencies of the federal government (e.g. NIH), prohibit faculty from devoting 100% of their effort to sponsored activities when their academic appointment requires them to be engaged in non-sponsored activities. As such, the following activities must be paid from sources other than sponsored funds unless they are specifically approved activities of a sponsored project:
- Clinical and professional activities such as seeing patients outside of the context of a sponsored human subject study, patients consultation, patient care, etc.
- University and public service (University service includes institutional governance, service on institutional committees, and department administrative activities)
- Preparation of new or competing proposals (unless current funding allows it, such as a K award)
More information on Effort Reporting is available on the Controller’s website under policy 300-20, Effort Reporting of Federally Sponsored Projects and the Effort Reporting FAQs.
IX. PROJECT COST OVERRUNS
Costs that exceed the budget on a sponsored agreement should be tracked and accumulated. The excess costs (i.e. deficits) must be transferred to a discretionary Fund-Project in accordance with policy 250-12, Deficit Monitoring and Resolution.
X. RECHARGE COSTING PRACTICES
A recharge is the assessment and collection by one university unit for products or services furnished to another university unit. The Campus Budget and Resource Management department has established policies and procedures for charging organizational units for products or services that include all allowable costs associated with providing the products or services.
Recharges must be charged to the benefiting activity. Recharge costs are allowable costs to a sponsored project as long as the department recharging the project has followed the guidelines in UCSF Administrative Policy 250-11, Recharges & Common Cost Allocations and the recharge rate(s) have been approved by Budget and Resource Management. See the Budget and Resource Management website for more information.
XI. ITS FIELD SERVICES
Consistent with Department of Health and Human Services, Division of Cost Allocation (DHHS-DCA) approval, UCSF charges federal awards for the operating and maintenance costs of data network and voice services through recharge rates. Beginning July 1, 2013, UCSF initiated, on a prospective basis, to direct bill funding sources including Federal awards for computing and communication device support services. Computing and Communication Device Support Services Support are an integral component of data and voice network services include software installation and updates, internet security, hardware configuration and setup, and backup and maintenance of central servers. Recharge rates for all of these services are based on a rate per FTE consistent with the current billing rates for data and voice network services. The recharge rates will be computed in accordance with the requirements of 2 CFR Part 200 Uniform Guidance and will be reviewed and adjusted annually. The related sections in the Uniform Guidance are §200.413 Direct costs. and §200.415 Required certifications.
These costs are treated by UCSF as direct service center costs and have been subsidized by university general funds. These subsidies have not been included in the F&A rate administrative cost pools and any immaterial amounts would have been excluded from the F&A rate due to the 26% administrative cap (contact Budget and Resource Management Office for detail analysis). These support services in conjunction with data and voice network services are covered under Part 3.2.0, Service Centers, Communication Services, of UCSF’s currently approved DS-2, Disclosure Statement.
Appendix A: Unallowable Costs
Uniform Guidance 200.403 defines allowable costs to a federal award if the goods and services are necessary and reasonable to the performance of the award. Those costs which do not meet the criteria defined per Uniform Guidance and conflict with award terms and conditions along with UCSF policies are unallowable costs. For guidance on specific cost types refer to Uniform Guidance sections §200.420 through §200.475 in conjunction with the award document.
Neither unallowable direct expense, nor the indirect expense related to the unallowable direct expense may be charged to a Federal award. Such expense may be charged to department discretionary funds or to non-Federal funds if appropriate to the terms and conditions of the non-Federal fund. If a particular item of cost is not mentioned in §200.420 through §200.475, then the intent is not to imply that a particular item of cost is either allowable or unallowable; rather, determination of allowability in each case should be based on the treatment provided for similar or related items of cost. In case of a discrepancy between the provisions of a specific sponsored agreement and the information below, the agreement should govern and the sponsor should be consulted.
If the Federal Award is charged for a cost that is initially paid and subsequently disallowed, then the Federal Award must be made whole. If the award has been paid final, then a refund payment may be required. (See §200.410)
The unallowable expenditure account codes on the left side of the table below must be used whenever the specific charges post to a discretionary fund source. Many unallowable accounts on the left-hand side of the table have an allowable account on the corresponding row on the right-hand side of the table. The account on the right may be used when the circumstances warrant an allowable direct cost expense or allowable F&A.
Appendix B: Frequently Asked Questions
Clarification of Terms Used in the UCSF Cost Accounting Standards Guidelines (CAS), Charging Practices for Sponsored Projects Document
- Under "Guidelines for Direct-Charging Administrative Costs to Federal Projects, Treatment of Administrative Salaries and Benefits on Extramural Funds, Standard Treatment (section IV, A, 1) UCSF CAS Guidelines," please explain the following, with examples:
- Administrative data entry Answer: This refers to data entry of an administrative nature such as collecting cost data and allocating costs to other projects, or preparing cost transfers to re-allocate costs to other projects.
- Maintaining departmental databases Answer: This refers to databases of an administrative nature, such as creating and maintaining departmental “shadow” financial systems; a database to maintain emergency contact information for all employees of a department or unit; a database that maintains the proposal and award data for a particular program.
- Who has the final responsibility to ensure that the charging guidelines are followed? Answer: The Principal Investigator has final responsibility for all charges appearing on his or her funds.
- Does UCSF have to be consistent even if the funding agencies are not? Answer: Yes. Cost Accounting Standards (CAS) guidelines apply to all federal funds (including federal flow through funds). CAS authority is delegated to the campus. The federal government does not override campus CAS guidelines. If the award is more restrictive than UCSF CAS guidelines, then follow the terms of the award. If the award is less restrictive than UCSF CAS guidelines, then follow CAS guidelines.
Types of Grants Affected
- Are General Clinical Research Center (GCRC) and Pediatric Clinical Research Center (PCRC) awards exempt from UCSF CAS guidelines? Answer: Yes, with regard to administrative costs. The F&A rate negotiated for the GCRC and the PCRC awards adjusts for Department Administration costs charged directly to these grants. Therefore, Department Administration costs should be direct charged. All other aspects of UCSF CAS guidelines apply to these grants. Note that federal funding for GCRCs and PCRC are now included within the larger Clinical and Translational Science Initiative (CTSI) award. For specific F&A information on these types of awards, please refer to Chart of Project Type and F&A Cost Rate found on the OSR Website
- Do the UCSF CAS guidelines apply to users of a CRC (Clinical Research Center) who are separately funded? Answer: Yes. Users of any CRC who are funded outside of the GCRC or PCRC awards themselves are under the UCSF CAS guidelines, if they receive full or partial funding from any federal awards.
- What types of grants are subject to the cost accounting standard charging practices? R37s? PPGs? Center grants? Answer: The UCSF CAS guidelines apply to ALL federal contracts and grants. This category includes contracts/grants from state, county, city, or private sponsors, which are fully or partially funded by the federal government (i.e. "federal flow-through awards").
- Could further guidance be given on Program Project Grants (PPGs) and other federal multi-project grants clarifying what is allowable and unallowable as direct charges under CAS? Answer: Routine administrative activities are not allowable as direct charges to federal grants, including PPGs and other multi-project grants. Routine administration includes the following actions: preparation of grant/contract proposals; personnel related activities such as preparation of PAFs, inputting changes to OLPPS, and hiring actions; routine purchasing; general ledger review; and preparing cost transfers.
However, non-routine administrative activities for awards that require extensive administrative support to carry out specific research aims and tasks and are directly attributable to the research outcomes are allowable.
Examples of expenses that would be allowable on these types of projects include the following:
- Administrative support for preparation of animal or human research committee application
- Preparing mass mailings for program surveys or patient follow-up
- Travel arrangements for site visits or investigator meetings
- Telephone surveys
- Extensive interviewing
- Collection and compilation of budgets or financials from all sub-projects in order to review overall budgetary or financial status of the entire project. This does not include routine day-to-day budget or financial related activities such as cost transfers or ledger review.
- Manuscript preparation
- Planning and organizing large conferences
- Central scientific data collection
- Project-specific computer programming and data entry
- Cell phone purchase and related phone charges for projects requiring immediate access to patients or other mandatory program requirements
- Preparing materials for subcontract documents, and reviewing subcontract invoices
- Performing laboratory activities
- Computer research work
- Grant-related transcribing, beyond the routine
- Individualized graphics or manuscript preparation
- Developing materials for presentation
- Furniture for scientific purposes (e.g., blood draw table)
- Are training grants subject to UCSF CAS guidelines? Answer: Yes. If they are federally funded, training grants are subject to UCSF CAS guidelines. Also, the funds awarded as training related expenses in many federal training grants must be spent in accordance with UCSF CAS guidelines.
- Do UCSF CAS guidelines apply to federal flow-through funds where the federal government does not pay any overhead? Answer: Yes, UCSF CAS guidelines do apply.
- Do UCSF CAS guidelines apply to municipal (i.e. city or county) and State of California contracts? If a municipal or state award were funded from a Federal Block Grant, would UCSF CAS guidelines still apply? Answer: Yes and no. Uniform Guidance and CAS principles do apply to municipal (i.e. city or county) and State of California contracts if they include, in full or in part, any funds from the federal government (i.e. federal flow-through funds). However, both the U.S. Department of Health and Human Services and the California Department of Public Health have stated that Uniform Guidance and CAS principles do not apply to Federal Block Grant/Funds type programs. At the time of proposal preparation, departments should work with UCSF's Contracts & Grants Office to make an accurate determination as to whether or not: 1) a city or state sponsored project is federally funded, and 2) if the project is funded under a Federal Block Grant/Funds program. See Uniform Guidance §200.101 Applicability for more detail.
- May “CAS–disallowed” expenses, such as General, Automobile, and Employee Liability (GAEL), be charged to partial federal flow-through funds like JPAs and some municipal contracts? Answer: Yes. The Costing Policy Group and the Budget and Resource Office had a consensus that the GAEL is applicable to anything other than fully funded Federal Awards (and Flow through code 3). Therefore, GAEL charges are allowed on JPAs from the NCIRE and some municipal contracts.
- What level of detail must be included in budget justifications? Must allowable costs be detailed out? Answer: Detail must be sufficient to enable reviewers to determine whether the costs are reasonable and allowable for conduct of the project. All justifications for costs that may appear to be administrative in nature, such as postage, telephones, etc., must show that they can be specifically allocated to the project and are required specifically for the project to meet its aims so that reviewers do not perceive them to be routine and cut funding for them. For example, the purchase of USB Data storage devices that will be used by multiple sites is an allowable cost. The purchase of paper for a shared copier, some of which will be used for the project but most of which will be used by the administrative office is NOT an allowable cost. Also, it is best to provide detail in the descriptions and narratives of the budget, but not to actually specify the dollar amount of costs to such a detailed level.
- May modular grants include items disallowed under the UCSF CAS guidelines since the NIH does not require a detailed description of the budget? Answer: No. Expenses must be allocated and accounted for in accordance with applicable cost accounting principles and the NIH Grants Policy Statement
Salaries, Wages, Benefits, and Effort
- Campus guidance directs that averaged or actual fringe benefits may be used in proposal preparation. How is consistency achieved in proposal preparation? Answer: UCSF CAS guidelines, federal agencies, and campus policy allow for benefit costs based on an average rate to be used in proposal budgets, but the charges are actual benefit costs incurred. For budget consistency, use salary escalation and benefit rates provided by the Office of Sponsored Research. It is generally acceptable under UCSF CAS guidelines to accumulate costs in more detail than they are estimated (i.e. charge costs in greater detail than budgeted). Using an average benefits rate to estimate costs, but then charging actual benefits is an example of this principle. However, it is not acceptable under UCSF CAS guidelines to budget costs in more detail than they are accumulated.
- If I submit a budget proposal at the highest salary cap allowed even though the PI is currently at a much lower salary rate, may the PI be paid the higher salary cap rate if the award is made at the full rate? Answer: No. Departments should submit budgets prepared using the actual salary cost, plus estimated merit increases as described in the salary and benefits guidance memo issued by the Office of Sponsored Research. It is fraudulent to request salary rates higher than those allowed by University compensation policies, or to allow a PI or staff to be paid a higher salary rate on the basis that the award provided funding at the higher rate.
- How should voluntary and mandatory cost sharing be handled? Answer: Please refer to the UCSF Cost Sharing Campus Administrative Policy 400-17 and UCSF Controller's Office Procedures on Cost Sharing for more information.
- If cost shared effort is associated with a grant, are fringe benefit charges allowed to the grant up to the percent of the cost shared effort? Answer: No. Fringe benefits must be charged to the fund that pays the salary.
- How is Effort Reporting related to CAS? How should cost sharing effort be reported? Answer: Effort reporting is used to report and certify paid and unpaid effort. Cost sharing effort is captured on an effort report. Certified effort reports are UC's method of documenting the distribution of personnel services as required by Uniform Guidance §200.430 Compensation—personal services. See section on “Standards for Documentation of Personnel Expenses”. More information can be found in UCSF CAS guidelines, Section VIII. Effort Reporting and the UCSF Controller's Office website on Effort Reporting.
- Research assistants whose duties directly benefit sponsored research have job titles "(blank)" Assistant I, II, and III because this is how Human Resources has classified these positions. Will new title codes be made available to differentiate legitimate direct activities for sponsored research? Answer: We are not aware of any current plans to create new title codes due to CAS. If the duties of these "(blank)" Assistant I, II, or IIIs benefit the "science of the project" and can be substantiated then their efforts devoted to the project may be direct charged to the project. Such efforts directly benefiting the science of the project should be explained in the project proposal.
- How should departments handle the minor administrative duties that a Staff Research Associate (SRA) performs? Answer: When an employee devotes minimal effort to a single function (including administration) which is considered immaterial, it is not necessary to separately identify it. There is neither a governmental, nor campus policy on what constitutes "minimal effort." As a guideline, this is generally no more than 5% FTE. This 5% guideline is an aggregate amount -- e.g. if the person devotes 3% administrative effort each to projects A, B, C, D, E and F, the total amount of administrative effort for the person is 18% which is material. Particular circumstances in individual cases may suggest a different threshold is appropriate. Uniform Guidance requires pre-approval of all administrative salary costs direct charged to an award except for awards from the NIH who has waived this pre-approval requirement. However, to be allowable, they must have been included in the proposal budget for all awards with appropriate justification. UCSF has determined that generally over 10% is integral to the project and therefore may be allowable.
- Are invoice reviews an administration activity? What about reviews of subcontract invoices? Answer: Yes, invoice review is an administration activity and should be charged as such. Where there is extensive review of invoices (or any other type of normally administrative activity) for subcontracts due to the nature of the arrangement, such costs should be direct charged. For example, an analyst who must review the invoices from multiple national and international institutions for one project could have the corresponding effort directly charged to the award. Also, see the question 7 in this section for a discussion on "minimal efforts" devoted to administrative duties.
- Is an Administrative Assistant II's time devoted to the paperwork surrounding traveling (e.g. advances, reimbursement, etc.) “routine" administration? Answer: No. Under UCSF CAS guidelines travel costs are considered beyond the routine and, therefore, should be direct charged to the appropriate benefiting activity or activities under CAS. This includes the costs of arranging and processing the travel. So to the extent the travel is allowed by the award and benefits the science of a project, the appropriate portion of the travel costs and of travel arrangement/processing costs should be directly charged to the project. One reason that such arrangement/processing costs might not be charged to an R01 or other grant is that the amounts are minimal, which is an aggregate of 5% or less during the budget period. See question 7 in this section for guidelines on minimal effort.
- What types of expenditures cannot be cost shared? Answer:
- For cost sharing on federal awards, any costs that would not be allowed on federal sponsored awards cannot be cost-shared. Like federal direct expenditures, cost-shared costs must be allowable, allocable, reasonable, and consistently accounted for by the University. Note that there is often more flexibility with cost sharing on non-federal awards.
- Costs that are paid by the federal government cannot be used to meet cost-sharing requirements on other federal awards unless authorized by federal statute.
- Costs representing salaries over regulatory caps, such as the National Institutes of Health salary cap, cannot be used to meet a cost sharing commitment
- May you budget for routine office supplies in a grant proposal? Answer: No. Routine office supplies such as pens, binders, copier paper, filing folders and bins, software licenses (e.g. MS Office) that can be used for other purposes are considered department administrative costs and should neither be budgeted nor charged to federal funds. Administrative supplies that may seem necessary for the operation of a laboratory or research site such as clocks, wastebaskets, and an erasure board should also not be budgeted nor charged to federal funds. Office supplies that are used for a scientific purpose and attributable to the research outcomes, like lab notebooks, graph paper, etc. may be direct charged to federal grants.
- May non-federal funds be charged for office supplies if it is within sponsor guidelines? Answer: Yes. While office supplies used for routine administrative activities are not to be charged to federally funded projects, sponsored project funds from private sources or state and local governments (except for federal flow-through awards) may be direct charged for this expense barring no exemptions per the award agreement. Printing, Publications, Photocopying, and Photocopiers
- May departments charge photocopy expenses to federal grants? Answer: No. Recharges to federal funds for routine photocopying should be redirected and charged as department administration. However, recharges for justified photocopying for the scientific aim of the project, such as brochures required for subject recruitment or questionnaires, should always be charged directly to the benefiting activity, even if that activity is a federally funded project.
- Are photocopies of journal articles an allowable expense on federal awards? Answer: Maybe. Photocopies of journal articles are an allowable expense when they are directly related to meeting the specific aims of the research project. For example, copies of journal articles used for the purposes of referring to other methodologies, reference articles, and/or findings on similar hypotheses can contribute to the conduct of the research. Photocopies of articles for general purposes that are not directly related to meeting the specific aims of the project are not allowed on federal funds. For example, copies for a journal are not allowable since they are considered an F&A cost and should be charged as department administration.
- How should we treat the costs associated with copying human subject certification forms? Answer: Copying human subject certification forms is program specific and should be direct charged to the project. It is also important that all projects with human subject certifications be treated consistently. So, for example, a privately funded clinical trial benefiting from human subject certifications should be direct charged all appropriate costs, including costs of copying the certification forms.
- How should departments treat the costs associated with the preparation of publications? May office supplies used for the publications be direct charged to the project? May the photocopy and office supply costs associated with surveys (e.g. epidemiological surveys) be direct charged to the project? Answer: Yes. Costs related to the preparation of publications, including the office supplies used, should be direct charged to the project. Costs associated with a survey that is part of the project should be direct charged.
Postage and Mailing
- Is the cost of mailing reprints allowable? Answer: Sometimes. If the reprints are needed for the performance of the science, the cost of mailing reprints is allowable as a direct charge. For example, reprints that are mailed to various investigators on a PPG who need information on the work that has been done. If the mailing of the reprints is not necessary for the conduct of the research then the cost of mailing should not be directly charged to the project.
- If one phone set in each lab is labeled "For Research Only" and is used only for sponsored research, may we charge the line charges, local and long distance calls on this phone to research? Answer: No. Local calls, line charges, and phone equipment costs are not normally allowable on research awards under the Cost Accounting Standards, although long distance charges may be allowable if they can be directly identified with the award easily and with a high degree of accuracy. An exception to this rule is the case of a sponsored project award where a phone line is required in order to perform a specific project function such as phone interviews with study subjects, or to monitor study patients. In this case, it is allowable to set up one particular phone dedicated solely to the one research project and then charge the full cost of the scientifically related telephone charges to that one award.
- We are currently charging telephone charges to our pro fees and charging federally sponsored projects for applicable long distance phone charges. Is this acceptable? Answer: Yes. This is acceptable. The local call, line, and equipment charges should be charged as Department Administration.
- If someone makes a personal call from a telephone line that is paid for by a federal source, may the person reimburse the university by making a deposit to a federal grant or would we need to move any personal call charges to an unrestricted fund and then reimburse that fund? Answer: Yes to the first option, no to the second. The University discourages the use of University telephones for personal calls. However, if someone makes a personal phone call, the reimbursement for that personal phone call should be posted to the same Award-Project as where the phone expense resides.
- Is the purchase of a cell phone and related monthly charges allowed on a federal award? What about a Personal Digital Assistant (PDA) device such as a Blackberry, iPhone, Palm, etc.? Answer: Maybe. The purchase of a cell phone or PDA and associated monthly fees is allowable on a federal award only if it is required for direct performance of a project. For example, if a PI needs to check in hourly on the status of patients participating in a federally funded clinical trial project, and the PI is frequently away from phone access (e.g. traveling between hospitals), then a charge of this type would be allowable. This direct charge must also comply with the reasonableness principle – as must any direct charge to a federal award. Use of a cell phone or PDA that is direct charged should be limited to the project from which it was purchased and should not be used for non-award related purposes.
- May a subscription be charged to a sponsored project if it benefits the specific project and several other projects, as well? Do we have to divide the cost among projects? Answer: Yes. You should prorate the charge using an identified allocation methodology. Subscriptions may be charged to a sponsored project if the periodical is not in the library and if it benefits the specific project.
- Do the charging guidelines regarding subscriptions apply to off-campus facilities (e.g., Fresno, China Basin)? Answer: Yes. The subscription guidelines apply to off-campus facilities. An exception is made with regard to the "if the periodical is not in the library" rule for off-campus facilities that are out of the area. For this purpose, "out of the area" means the facility is one outside of San Francisco and northern San Mateo counties (north of Interstate 380). Please note that the Medical Education and Research Center (MERC) library at UCSF Fresno is considered an “on-campus” facility.
- Are books for trainees allowed on a training grant even though a single copy may be found in the library? Answer: Yes. The trainee allowance under a training grant may be spent on anything related to the training. It would be permissible to buy such books out of the allowance, provided they significantly benefit the training covered by the grant.
- Membership to a particular professional association includes a subscription to a professional journal that is not in the UCSF library. May I charge the membership cost (that includes the journal) to the grant in order to subscribe to the journal? Answer: Maybe. The cost of a membership is always an F&A cost (e.g. Department Administration), and should not be charged directly to a federal grant. Subscriptions may be a direct cost provided the journal is not available in the campus library and that the journal benefits the scientific aims of the project. If the journal is available in the campus library, then the cost is an F&A one. To the extent that it is possible to reasonably separate the cost of the membership vs. the cost of the subscription, the two costs should be charged differently in accordance with the UCSF CAS guidelines. If it is not possible to reasonably separate the membership and subscription costs, then the entire amount should be treated as a membership. The best way to document the separate costs would be via written documentation supplied by the professional association.
Repairs, Maintenance, and Janitorial
- May we establish a recharge methodology to recharge grants for a repair and maintenance contract on equipment, such as sophisticated computer and electronic equipment whose use is solely to benefit research, but which benefits a number of different sponsored projects? Answer: Yes. See UCSF Policy 250-11 Recharge Activities & Common Cost Allocations and the Budget and Resource Management recharge website for information on establishing a recharge.
- Does "special needs cleaning" include extra lab cleanings for patients with asthma or other conditions? Answer: If the project involves patients with a particular condition, such as asthma, and the laboratory's condition is such that it requires special cleaning for the benefit of these patients, the cost of the special cleaning is program specific and therefore should be direct charged.
- How do we recharge lease, rental, and utility costs among grants that share rented/lease space? Answer: Departments must use a recharge methodology approved by the campus Budget and Resource Management department. Using the ratio of square footage is almost always an acceptable methodology. Other methodologies will be considered on a case by case basis. For leased space off-campus, all operation and maintenance costs must be covered by the recharge under full costing policy. See UCSF Policy 250-11 Recharge Activities & Common Cost Allocations and the Budget and Resource Management recharge website for more information.
Subcontracts and Subrecipients
- What are department responsibilities in regard to monitoring budget proposals of subcontracts under federal projects? Specifically, if an unallowable CAS item appears on a subcontract budget proposal, how should the department respond? Answer: Under Uniform Guidance, the prime recipient (the UCSF in this case) is responsible for adequately monitoring sub-recipient compliance with federal rules in the applicable circumstances. Applicable CAS rules will apply to subcontract awards under any one of the following circumstances: (1) the subcontract is to an institution of higher education that is under Uniform Guidance, (2) if the prime agreement at UCSF is a federal contract containing the appropriate CAS-related Federal Acquisition Regulations (FAR), or equivalent clause, or (3) if the subcontract is for $500,000 or more. In any of these cases, a department should review the subcontract budget for CAS compliance. If the department has a question about any budget items, they should inform the subcontracting entity that they believe there is a potential CAS problem. Resolution will be either: 1) the subcontracting entity modifies the budget, or 2) the subcontracting entity provides the department with a written statement that the budget was prepared in compliance with federal costing policies applicable to the subcontracting entity. It is important to note that the applicable federal costing policies vary by the type of entity -- university, other non-profit, or for profit (see following question).
- What are the applicable federal costing policies subcontractors should follow? Answer: The applicable federal costing policies depend on the type of organization the subcontractor is. Generally they will be as follows:
For Universities or Colleges -- Office of Management and Budget Uniform Guidance (formally A-21)
For Hospitals -- Department of Health and Human Services OASC-3 Appendix E (formally Title 45 Code of Federal Regulations Part 74)
For State or Local Governments -- Office of Management and Budget Uniform Guidance (formally A-87)
For Other Non-Profit Entities -- Office of Management and Budget Uniform Guidance (formally A-122)
For For-Profit Entities -- Federal Acquisition Regulations (FARs)
- We currently have a subcontract (federally funded) with a non-profit as the prime that does not meet the threshold dollar requirements of $500,000 for CAS. The prime organization is not under the CAS requirements. Does this mean that CAS requirements do not apply to UCSF as the subcontractor? Answer: No. UCSF is under CAS requirements for this subcontract as the CAS rules apply to all federal flow through funding received at UCSF.
- What are the guidelines and responsibilities for detailed management of subcontracts under our federal grants? Since the invoices have only the broad categories of expenditure, we do not see detail and do not know if compliance with CAS is being fully maintained. Answer: When working with subcontracts under prime UCSF contracts and grants, departments should focus on proposal submission as the time to review subcontracts for compliance with CAS. As invoices do not necessarily contain detailed line items, it is not always possible for departments to view individual charges or items that might raise a CAS concern. However, departments should continue their usual review for compliance with applicable federal grant rules and regulations. Currently, subcontracts issued by UCSF contain language requiring the recipient to comply with federal rules, including CAS. The Principal Investigator is ultimately responsible for post award management of the subcontracts.
Other Specific Kinds of Expenditures
- Are recharges for the disposal of bio hazardous waste which directly benefit a specific research project considered allowable on federal funds under CAS? Answer: Yes. At UCSF, the cost of any hazardous waste disposal should be direct charged to the activity producing the waste, including federally funded projects. It has been UCSF's policy to treat hazardous waste disposal as a direct cost, and UCSF's F&A rate does not include any hazardous waste disposal costs. This treatment by UCSF is consistent with Uniform Guidance and CAS. It is, however, different from many other universities, including some other UC campuses, which treat hazardous waste disposal as an F&A cost.
- May federal funds be used to purchase furniture? Answer: Maybe. Furniture is defined as movable items of convenience such as tables, chairs, desks, etc. used to furnish an office or lab. It is considered equipment if it is over the $5000 threshold or supplies if it is under the $5000 threshold. Whether or not it is classified as equipment or supplies, furniture may be direct charged to a federal fund only if it is used for a scientific, medical or other technical activity that benefits the project. This applies regardless of whether the furniture will be used at an on- or off-campus location. For example, a table and chair that are needed for interviews with a project's study subjects and specifically designated solely for that purpose could be an allowable direct charge, whereas, a desk or a chair for project staff would not be an allowable direct charge.
- May departments charge sponsored projects for the cost of an annual retreat? Answer: Maybe. If the conference is scientific and is allowed under the terms of the award, then it may be direct charged to the federally funded project. If the conference is of a general nature, then it may not be direct charged to a federally funded project. See UCSF Policy 250-11, Recharges & Common Cost Allocation, Appendix A (Charging for UCSF Sponsored Conferences and Continuing Education Type Courses) for further guidance.
- Are lab coats and lab related laundry allowed to be charged on R01 grants? Answer: Maybe. Lab coats and lab related laundry charges should be charged to federal grants when the amounts are reasonable and benefit the projects. Often, lab coats and laundry charges benefit more than one project or activity, possibly including Instruction activities. If so, some reasonable allocation of the costs among the projects and activities is needed. It is also important that all projects or activities that benefit from the lab coat or laundry service be treated consistently. So, for example, a privately funded research project benefiting from laundry service should be charged the appropriate share of the laundry service's cost, or a lab coat benefiting Instruction should be charged to an Instruction function.
- Are employee badges ever allowed to be charged to federal funds? Answer: No. Employee badges are considered part of personnel administration and, so, should not be charged to federal funds.
- May cost of door nameplates for new employees be charged directly to their funding projects? Answer: No. Employee nameplates are considered part of personnel administration and, so, should not be charged to federal funds.
- May federal funds be used to pay for health insurance for family members of a post-doctoral fellow working on a federal grant? Answer: Yes. Federal funds may be used to pay for a post-doctoral fellow’s health insurance plan in proportion to the amount of effort on the project.
- May the "Institutional Allowance" awarded under the National Research Service Awards (NRSA) be used to pay for the fellow's family health insurance? Answer: Yes. Please see NIH Grants Policy Statement on Training Grants.
- A fellow in the department needs to take a language class. If he or she is paid on a federal grant, may the cost of the class be charged directly to that grant? Answer: No. Such classes are not related to the "science" perspective of the project and should be paid by discretionary funds.
- May training for administrative staff be allowed on a federal grant? Answer: No. Training is not allowed, unless the course directly benefits the science of the federal grant.
- I have a few clinical fellows on an NIH T32 grant who see patients and need to carry pagers. Is the cost for their pager service an allowable direct cost? Answer: Maybe. As long as there are no restrictions on the grant regarding pagers, and seeing patients is part of the scientific aims of the project, the cost is an allowable direct cost. However, if the pager is also used for other clinical or other purposes outside of the T32 grant, it should be charged in a proportionate manner.
- To attract a large pool of candidates for an Adjunct Assistant Professor position that will act as Principal Investigator of a federally funded award, we advertised the position in three scientific journals. May these advertising costs be direct charged to the award in question? Answer: Maybe. If you are recruiting for a replacement PI who will be devoting 100% effort to the award, the advertising costs may be directly charged to the project. If the effort of the PI is split between the federally funded project and other activities, e.g. Instruction, Other Sponsored Activities, the advertising costs should be proportionally charged to these activities. See Uniform Guidance section §200.421 Advertising and public relations.
- Are entry visa filing fees and premium processing fees allowable costs on federally funded grants? Answer: Yes and no, respectively. Entry visa filing fees for non-student employees working on grant and contract awards are allowable on federal awards. These should be budgeted in the “other costs” category and charged proportionate to the level an individual is working on an award. The account to use for entry visa filing fees is 57810. Premium entry visa processing fees for non-student employees that provide an expedited review of an entry visa application by the government are not allowable on federal awards. The account to use for premium entry visa processing fees is 57813. See Uniform Guidance section §200.463 Recruiting costs.
- Can I charge human subject protocol review fees (aka IRB fees) to sponsored awards? Answer: Sometimes. Industry sponsored awards may be charged IRB fees. Government and non-profit awards may not be charged IRB fees unless approved by the sponsor.
- How should cost overruns be handled? Answer: Cost overruns occur when actual project costs exceed the sponsor's funding. Actual project costs should be accumulated in the sponsored project even if this creates a deficit situation. The deficit should be cleared before any reporting to the sponsor by posting a deficit transfer journal as follows: Use Journal Source Code 547.
- Credit the sponsored project using account 58351 for the *lump sum amount of the deficit to be transferred.
- Debit a departmental discretionary funding source also using account 58351 for the *lump sum amount of the deficit to be transferred.
- It is critical that both the debit and credit entries of the journal use account 58351
- The lump sum should be the direct cost of the deficit
- My department Chair wants to issue "clearer guidelines" on CAS to department personnel. How should I proceed? Answer: UCSF wants to maintain as much flexibility as possible while also complying with the CAS requirements. There has been relatively little definitive guidance from the federal government on what are allowable vs. unallowable practices under CAS. All definitive federal guidelines are included in the campus issued Cost Accounting Standards (CAS) guidelines. The campus issued this document, and the related training materials, with the intent of meeting the needs of management and CAS compliance given the best information available. Departments issuing "clearer guidelines" for charging than those already issued campus-wide could potentially result in the following consequences: 1) decreased charging flexibility, 2) raise a consistency issue if other departments do not also issue "clearer guidelines", and 3) raise a consistency issue if one department's "clearer guidelines" conflict with another department's "clearer guidelines" regarding a particular charging practice. We therefore discourage departments from issuing their own "clearer guidelines." Departments are welcome to submit questions to get additional clarification of these guidelines. As appropriate, the Guidelines will be updated so that all departments may benefit from the clarifications or additional information. Inquiries and suggestions should be directed to Nilo Mia ([email protected]) or Matt Suelzle ([email protected]) in Budget and Resource Management.
Appendix C: Allowability of Meals on Sponsored Project Awards
Entertainment costs, such as meals, are normally an unallowable expense on federal sponsored project awards. Where meal costs have a programmatic purpose and are authorized either in the approved budget for the Federal award or with prior written approval from the sponsor they may be charged as a direct cost to the award. Pursuant to federal policy, UCSF has developed the following guidelines to govern expensing the cost of meals to sponsored project awards.
UCSF Guidelines on the Allowability of Meals on Sponsored Project Awards:
When charging meals (other than those allowed under award terms) on a sponsored project award at UCSF, the following principles must be adhered to:
The cost of meals provided for meetings for the express purpose of the dissemination of scientific project-related information must be included in the proposal budget and budget justification, and subsequently be approved by the awarding agency. If an awarding agency disallows any proposed meal costs during the proposal review process then those meal costs should not be charged to the award.
Meals are not allowable for routine internal business meetings, such as periodic (weekly/monthly) scientific or administrative staff meetings.
- All meal charges must follow basic principles of reasonableness. Accordingly, meals must not exceed the then-current reimbursable cost of the applicable meal under the UCSF Travel Policy at the time of the meeting and the items expensed must be allowable under federal cost principles.
- These guidelines must be applied consistently on awards, regardless of whether the meeting is funded by the federal government or another sponsored project source such as a non-profit award.
- In rare instances, it may be allowable to hold an emergency project meeting and charge a sponsored project award for meals. For example, meals may be allowable in the case of an emergency meeting for the purpose of training nurses/coordinators working on a clinical study on the adverse impacts of a drug under study, or on a project where there are imminent human safety concerns that must be addressed. In these rare instances, you may be able to utilize re-budgeting authority to accommodate the cost provided there are no restrictions applicable to the particular award. Proper documentation of the reason for the emergency meeting should be maintained for audit purposes.
- Note: Meals are allowable when project staff travel to outside scientific conferences (such as an annual AIDS Conference) as approved under grant terms and in conformance with the UCSF Travel Policy. Allowable costs for conference travel include the cost of meals, transportation, registration fees, or other items incidental to such travel.
Questions related to meal allowability on proposals should be directed to the RMS team responsible for the proposal submission. Questions related to the allowability of meal expenses on awards should be directed to [email protected]
Appendix D: Charging Maternity Leave, Employee Separation Administrative Costs, and Award Termination
Generally, UCSF employment policies make a distinction between maternity leave and parental leave. Maternity leave is treated as short-term disability. Faculty and staff should consult an Academic Personnel representative and a Benefits Representative regarding the details of a pregnancy disability leave. In general maternity leave pay is under the University’s Pregnancy Disability Plan. Compensation to the employee on maternity leave cannot be charged to sponsored awards Specific awards may have language which allows maternity leave to be charged to the award.
Q: How many weeks of maternity leave can I charge to a federally sponsored project?
A: None unless it is allowed specifically by the type of award. In general UCSF maternity policy for birth and adoptive mothers begins two weeks before birth and end six weeks after the birth (eight weeks for caesarian section). The maternity leave pay is under the University's Pregnancy Disability Plan. The eight weeks of short-term disability is a fringe benefit and is funded centrally; it cannot be charged to sponsored awards and is not considered paid time.
Q: What should be done if paid effort continued to post to the federal fund during the maternity leave, even though the faculty member was not actually providing effort during this time?
A: If effort was posted to a federally sponsored project while the employee was on short-term disability under the University’s Pregnancy Disability Plan, the expenses would need to be transferred off the sponsored project using a payroll expenditure transfer (PET) and transferred to the appropriate departmental fund.
Q: If additional funds are provided to the department to defray the costs of the paid leave is this a form of cost sharing?
A: No this is considered voluntary uncommitted cost sharing.
- References: Academic Personnel Policy 760: Family Accommodations for Childbearing and Childrearing
- Pregnancy, Newborn Child and Adopted Child Fact Sheet
The termination of an award prior to the end date may result in the incurrence of costs, which may be charged to the award. Refer to Uniform Guidance §200.471 to determine allowability The Federal Award should be charged for the costs which are exclusively for the terminated award. The responsible Research Support Administrator (RSA) must identify items which have not been paid, such as purchased items in transit from the supplier, subcontract invoices, and consultant invoices which have not been presented at the time of award termination. The department will need to negotiate settlement of these items with the Federal Award Contracting Officer.