Here is the link to OMB Circular A-21 Exhibit C.  This explains when a project may consider costs which are normally treated as F&A as direct costs.  Large, complex projects is at the top of the list.  However, although costs may be allowable, they should be justified to show that they are also allocable (tied back to the scope of work) and reasonable (you don't need leather portfolios for the annual report).

Two things to make sure you do in your budget justification:
1.  Tie each cost back to your scope of work (These paper products will be used for the Administrative Core in the production of the Executive Committee report as noted in the Introduction.)
2.  Itemize the items you will use in order to show allocability for each.

This is a bit of work, but when the internal accountants or external auditors have a question, it's already answered for them... and it will save you time and headaches in the long run.

Here's that web address:
http://www.whitehouse.gov/omb/circulars/a021/a021.html#exc

Jennifer

Jennifer Morgan, MHA

Vice Chair for Research Administration
Department of Psychiatry and Behavioral Science

Southern Section President
Society of Research Administrators International

Medical University of South Carolina
67 President Street, Suite 504
Charleston, South Carolina  29425

voice:  843-792-0191
fax:  843-792-0048
email:  xxxxxx@musc.edu

>>> xxxxxx@musc.edu 10/13/04 02:38PM >>>
Amy,
They are typically appropriate costs in the budget of the Administrative
Core of a Program Project or Center grant.

Occasionally on other grants, what appears to be administrative may in
fact be a direct cost allocable to a specific project.  An example would
be for behavioral science or projects with mass mailings.  In these
cases, paper for behavioral scales or mailings (necessary for the
performance of the grant) would be no different than a test tube for
basic research.  The key would be whether these costs are given
consistent treatment of application with established institutional
policies and accounting principles at your institution generally,
including sponsored agreements.

Susan

--
Susan A. Brown, C.R.A.
Grants & Contracts Administrator
Medical University of South Carolina
Research & Sponsored Programs
19 Hagood Avenue, Room 606 (express mail & drop +4 zip code)
P.O. Box 250808 (U.S. Postal Service only)
Charleston, SC  29425-0808
PH:  843-792-2040 (my desk)
PH:  843-792-3838 (receptionist)
FX:  843-792-6447

Amy E. Hibbard wrote:

>Hello all-
>
>According to A-21, including costs for general office supplies in grant
>budgets is a no-no.  But a PI argues that with large center grants, for
>which they will compile large reports and share information with 2-3
>other institutions, these expenses are necessary and required to make
>the project feasible.
>
>
>
>Have you included general office supplies (paper, printer toner, etc.)
>in large multi-institution grants?  If so, has it been funded?
>
>
>
>Thanks,
>
>-Amy
>
>
>
>~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>
>Amy Hibbard
>
>Grant Development Associate
>
>Office of Research & Sponsored Programs
>Cal Poly Pomona
>3801 West Temple
>Pomona, CA 91768
>(909) 869-6929 Voice
>(909) 869-2993 Fax
>
>xxxxxx@csupomona.edu
>
>
>
>"Opportunity is missed by most people
>
>because it is dressed in overalls and looks like work."
>Thomas Alva Edison
>
>
>
>
>
>
>
>
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