Re: Applicability of A-21 Greg & Peg Schmidt 04 Mar 2004 22:41 EST
I agree with what Mr. Chermside wrote here. To add to what he said, if in doubt, write a letter to the grants manager at the agency requesting clarification. I have seen auditors who have deemed as unallowable costs that were generally budgeted and accepted (via funding the costs). Their logic was that part of their audit involves a review of the granting agency's administration of their awards. Just because a cost was authorized via a budget document doesn't make it allowable under A-21. However, if they have specific documentation concerning a cost, they will usually accept it. Greg Schmidt Herbert B. Chermside wrote: > A-21 applies solely to federal funds, whether prime awards or > flow-down. Many institutions have internal or other externally imposed, > policies on allowability which are similar, but usually also have funds > without these limitations. Note that some costs allowable under A-21must > be indirect rather than direct costs; some of that depends on the > structure > of your F&A agreement with your cognizant agency. > > If the programs you mention are federally funded, A-21 applies, as to > charges allowable against federal funds. The projects might have at > their > disposal funds which do not have these limits. They must clearly > differentiate the accounts to which the charges are made. > Allowability of > costs is directly tied to funding sources. > > Certain costs which are largely unallowable as direct costs might be if > specifically budgeted and justified in proposals and the proposal is > accepted by the funding agency. F 6 (b) costs are an example; in some > cases they may be directly related to the project. > > Sounds as if you need clear internal rules on what may and what may > not be > spent on projects, with provision for clear documentation of "grey"areas. > > Chuck > > > > > At 03:36 PM 3/2/2004, you wrote: > >> We have a department on campus that runs workshops and externally >> sponsored programs to promote such things as minorities in engineering, >> women in engineering, programs to improve student retention and so >> on. Their spending habits give our accounting department grey hair. >> They >> purchase items such as small gifts and promotional materials for these >> programs and gifts for volunteers that act as peer mentors etc. >> >> The question is this, since these are non allowable expenditures as per >> A-21, does A-21 apply to programs of this nature and if so how do you >> reconcile these kind of expenditure activities which are essential to >> the >> operation of these types of programs? >> >> Mike >> Michael P. Gilles >> Senior Contracts Analyst >> Research & Sponsored Programs >> Michigan Technological University >> 1400 Townsend Drive >> Houghton, MI 49931 >> Ph: 906 487-2225 Fx: 906 487-2245 >> >> ====================================================================== >> 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 > Virginia Commonwealth University > PO BOX 980568 > Richmond, VA 23298-0568 > Voice: 804-827-6036 > Fax 804-828-2051 > e-mail xxxxxx@vcu.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") > ====================================================================== > ====================================================================== 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") ======================================================================