If PPE is being purchased by a central (EH&S?) office and distributed to labs, then it should be considered an indirect cost.  If faculty need to purchase PPE themselves in order for their group members to conduct research, then it is necessary for the research to be conducted in that lab and should be allocated among the PI's projects using the same rational methodology that other items such as gloves, plastics, common-use chemicals, etc are allocated.  If specific PPE is required to conduct a specific activity (i.e. interviews with human subjects) for a specific award, then it should be charged to that specific award.  The vast majority of agencies/awards allow rebudgeting between cost categories, and nowhere is PPE defined as an unallowable cost, so I wouldn't worry about it not being specifically called out in a budget justification.  Some federal agencies are allowing federal funds to be used for donation of PPE to hospitals--why on earth wouldn't they allow it for research to be conducted on a project?

If your university is demanding that PPE be treated as an indirect cost, I would say that your university should either be providing the PPE to labs or providing PIs with the additional funds required to purchase the PPE.  You put PIs in a very difficult situation if you tell them PPE has to be treated as an indirect cost and then don't give them the funds from the indirect cost pool to purchase the PPE.

Heather

Heather Sears, PhD
Contracts & Grants Manager
UCSD Department of Chemistry and Biochemistry
Urey Hall Addition 2050
858-534-3574

-----Original Message-----
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> on behalf of Michael Spires <xxxxxx@OAKLAND.EDU>
Reply-To: Research Administration Discussion List <xxxxxx@LISTS.HEALTHRESEARCH.ORG>
Date: Wednesday, May 20, 2020 at 7:43 AM
To: "xxxxxx@LISTS.HEALTHRESEARCH.ORG" <xxxxxx@LISTS.HEALTHRESEARCH.ORG>
Subject: Re: [RESADM-L] Allowability of PPE on Sponsored Awards

    Really? I'd argue that PPE is at least as allocable to a specific project as
    routine lab supplies and chemicals are. And in your last sentence, did you
    mean PIs or program staff?

    Michael
    (He/him/his)
    (248) 370-2207
    xxxxxx@oakland.edu

    Oakland University has taken steps to slow the spread of COVID-19.
    Nevertheless, the Research Office is available to faculty and staff for all
    the research development, proposal submission, and award management services
    that we routinely provide; please reach out to us through email (first
    preference) or phone.

    -----Original Message-----
    From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On
    Behalf Of Murphy, Chris
    Sent: Wednesday, May 20, 2020 10:29
    To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
    Subject: Re: [RESADM-L] Allowability of PPE on Sponsored Awards

    Our current position is, because PPE items cannot be assigned to specific
    projects with a high degree of accuracy, they should be treated as an
    indirect cost.  For projects that required special protective equipment
    because of the nature of the experiment, those charges would still be
    allowable.  But PPE is not an allowable direct charge to grants in response
    to COVID-19.
    PI's are already pushing back regarding this matter.

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