Presentation Transcript

1. Facilities & Administrative Cost Rate Issues

   Presented for the Alabama Research Symposium Cindy Hope – AVP Research, The University of Alabama
2. 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.)
3. Research Rate: F&A Calculation NUMERATOR = F&A Rate DENOMINATOR
4. 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)
5. 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
6. 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.
7. Questions?