Hi, all --

The finance VP at my organization has asked me a very basic grant accounting
question, and my forte is not in post-award issues, so I'm asking you all
for help. We are a not-for-profit health care center (not university
affiliated, not presently conducting any grant-funded research projects,
though we do have federal grant expenditures which approach/exceed $300K
annually -- we are apparently right on the bubble until we can make a
determination about some of the state flow-through awards). We have not
(yet) negotiated a federal indirect cost rate, but we are researching that
issue.

Here is the VP's question:

Are awardees of federal grants required to operate cost accounting systems
to demonstrate that even direct costs are providing identifiable benefit to
work for which a particular grant is awarded?  I ask because both A-21 and
45 CFR 74 App. E, in "Basic Considerations," specify that even direct costs
must be identified by "conforming to generally accepted cost accounting
practices consistently followed by the institution."

-----------------
Molly Daniel
Grants Specialist
Planning Dept.
Sarah Bush Lincoln Health Center
1000 Health Center Drive
Mattoon, IL 61938-0372
tel. 217-258-2195
fax 217-258-4135
email: xxxxxx@sblhs.org <mailto:xxxxxx@sblhs.org>
web: www.sarahbush.org <http://www.sarahbush.org>

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