Facilities administrative cost rate issues
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Facilities & Administrative Cost Rate Issues. Presented for the Alabama Research Symposium Cindy Hope – AVP Research, The University of Alabama. OMB Circular A-21: Factors affecting allowability. Consistent treatment

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Facilities & Administrative Cost Rate Issues

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Facilities administrative cost rate issues

Facilities & Administrative Cost Rate Issues

Presented for the Alabama Research Symposium

Cindy Hope – AVP Research, The University of Alabama


Omb circular a 21 factors affecting allowability

OMB Circular A-21: Factors affecting allowability

Consistent treatment

  • Allocating costs incurred for the same purpose: “All costs incurred for the same purpose, in like circumstances, are either direct costs only or F&A costs only with respect to final cost objectives.” (OMB A-21, §C.11.a.)


Research rate f a calculation

Research Rate: F&A Calculation

NUMERATOR

= F&A Rate

DENOMINATOR


Omb circular a 21 factors affecting allowability1

OMB Circular A-21: Factors affecting allowability

Consistent treatment

  • Salaries of administrative or clerical staff

  • Normally F&A cost (i.e. not allowable as direct charge)

  • Exception ONLY allowed for major project (F.6.b.(2))

  • What’s a major project? Examples found in A-21, Exhibit C

  • Office supplies, postage, local telephone costs, and memberships

  • Normally F&A cost (i.e. not allowable as direct charge)

  • Exceptions ONLY for different purpose or circumstances (CAS 502)


Omb circular a 21 factors affecting allowability2

OMB Circular A-21: Factors affecting allowability

Consistent treatment

  • New proposal preparation: CAS 502, Interpretation (c) - proposal costs are indirect unless “pursuant to a specific requirement of an existing sponsored agreement”

  • Other

  • Follow your Institution’s policy regarding what it treats as normally direct versus normally indirect.

  • Disclosure Statement

  • Auditors will expect documentation AND to find that there are REALLY exceptional circumstances


Regulations policies procedures factors affecting allowability

Regulations, Policies & Procedures: Factors affecting allowability

Consistent treatment: Audit example

  • 01/16/09 – Review of Administrative and Clerical Costs at Duke University (HHS OIG)

    • http://www.oig.hhs.gov/oas/reports/region4/40501014.pdf

  • Moral of the Story – Immaterial inconsistencies can result in material findings.


Facilities administrative cost rate issues

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