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- This chapter will provide the Principal Investigator (PI) with important
financial compliance information applicable to Federal Awards. The
information contained is based on the Office of Management & Budget
(OMB) Circulars A-21 and A-110. The applicable provisions of these
federal documents have been incorporated into the University’s
policies and procedures governing the expenditures of federal funds.
- What are the special characteristics of Federal awards?
- Federal awards are governed by standardized rules and regulations which
are stated in Office of Management & Budget (OMB) circulars and
Federal Acquisition Regulations (FAR). Rules for the determination of allowable
costs must be understood and followed.
- Award costs are subject to audit by federal auditors.
- Noncompliance with applicable provisions of federally funded contracts
or grants may result in disallowed costs, negative publicity for the
university, and loss of on-going collaborative relationships with
funding agencies.
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- OMB Circular A-21 establishes principles for determining what costs may
be charged to federal agencies’ awards for sponsored
projects. These principles
also apply to federal pass-throughs (federal funds which are awarded to
us from another university, private business or a state agency).
- A-21 mandates that costs must be:
- Allowable under the provisions of the circular and the terms of the
award.
- Allocable – The project which paid the expense must benefit
from it.
- Reasonable – A “prudent person” would have paid
this amount for the goods or services.
- The terms of a specific award take precedence over provisions of
Circular A-21 if the terms of the award are more restrictive. An award
cannot allow costs which are unallowable in OMB Circular A-21.
- OMB Circular A-21 regulations require the University to ensure that the
costs of research support personnel and other supporting expenses are
handled consistently across the University.
- Section D.1 of OMB Circular A-21 states:
- “Costs incurred for the same purpose in like circumstances must
be treated consistently as either direct or indirect costs. Where an
institution treats a particular type of cost as a direct cost of
sponsored agreements, all costs incurred for the same purpose in like
circumstances shall be treated as direct costs of all activities of the
institution.”
- The following material elaborates on direct and indirect costs and
justifications for exceptions.
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- The following costs should always be treated as direct costs when
developing a budget for a specific sponsored project:
- Salaries of faculty, technical staff and research assistants.
- Laboratory supplies.
- Animals and animal care.
- Computer costs.
- Travel costs.
- Telephone Toll Charges (long distance).
- Specialized Service Facilities costs (including specialized shop
costs).
- Direct charging of these costs may be accomplished through the specific
identification of individual costs to sponsored project objectives which
are to benefit, or through recharge centers, or specialized service
facilities, as appropriate.
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