We take a similar approach to this, also.  I think "avoidance" of
addressing this maybe describes our approach.   I think this type of
treatment of costs goes on somewhat naturally on its own and we
would use this authority to defend any such practice questioned in
an audit, but we don't encourage it's use. Too hard to set limits and
too easy to abuse! The only time we encourage it is, as noted in Mr.
Chermside's response, when we are to share in the cost of
equipment, etc.

Date sent:              Thu, 17 Oct 2002 10:33:33 -0400
Send reply to:          Research Administration Discussion List <xxxxxx@hrinet.org>
From:                   "Herbert B. Chermside" <xxxxxx@VCU.EDU>
Subject:                Re: [RESADM-L] Reporting of interdisciplinary awards
To:                     xxxxxx@HRINET.ORG

On the whole, we avoid using that authority.  There is too much room for
auditors having different judgements than "the University" does as to
relatedness.

I am sure PI's that have three projects buy supplies that benefit all their
work first on one and then on another account.  On occasion we may
split-code (charge two accounts), but really try to avoid it.

Never split-code project account and University account, unless it is a
very unusual circumstance, e.g., mandatory cost sharing of a big piece of
equipment; even there we'd rather do the cost sharing with different pieces
if possible.

We just don't want auditors to have a reason to go looking for trouble.

Chuck

At 09:49 AM 10/17/2002 -0400, you wrote:
>Dear Colleagues,
>An interesting policy consideration has reared its head.   I hope you can
>offer advice or helpful war stories.
>Under A-21 paragraph C.4.d (3), costs may be allocated among interrelated
>projects supported by multiple federal awards without prior approval or
>prior stipulation of relatedness.  How do you apply this in practice?
>Presumably since the federal regulations do not set limits, institutions
>probably do.  So, my bottom line question is what restrictions does your
>institution place on such expenditure allocations and what, if any,
>problems result.
>Thank you for any guidance you can offer.
>
>Ruth Smith
>Executive Director
>Old Dominion University Research Foundation
>Ph 757-683-4293, ext. 600
>Fax 757-683-5290
>Mobile Ph 757-469-5675
>
>
>======================================================================
>  Instructions on how to use the RESADM-L Mailing List, including
>  subscription information and a web-searchable archive, are available
>  via our web site at http://www.hrinet.org (click on "Listserv Lists")
>======================================================================

Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Express Delivery Only:
 Sanger Hall, Rm. 1-032A
 11th & Marshall Streets
 Richmond, VA  23219
Voice:  804-828-6772
Fax     804-828-2521
OFFICE e-mail   xxxxxx@VCU.EDU
Personal e-mail xxxxxx@vcu.edu
http://views.vcu.edu/ospa/
VCU will close its faculty and staff offices, including this one,  from
December 21, 2002 through January 5, 2003.

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================

Shannon Fisher
Assistant Controller
Kansas State University Controller's Office
Sponsored Projects Accounting
785-532-6207
xxxxxx@ksu.edu

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================