Re: Budgeting for Radiation Waste Disposal Doyle-Wandell, Greg 15 Jul 2005 15:06 EST
Brian My experience and perspective is that you should be able charge radiation waste disposal as a direct charge. However, you will have to explain it again, and again and again to funders, auditors, and every other individual who has seen it as an indirect cost. As a result, you might as well confirm this approach with your contracting officer and/or your auditor before you get too far out on a limb It may be perfectly appropriate for a large medical research institution to charge radiation waste disposal as an indirect cost, but for Eastern Michigan University treating it as a direct cost may be the correct approach. Neither is right or wrong. The determination of whether it is direct or indirect is dependent upon your cost structure, business practices and other factors, and may not correspond to what other institutions are doing. Beyond allowable, reasonable and allocable, you have already given yourself the justification to charge it as a direct cost: "the individual costs can easily be isolated and allocated to individual grant projects." As long as you have an auditable basis to charge a particular grant, and it meets the allowable and reasonable tests, you should be fine. Greg ============================ Greg Doyle-Wandell Director of Sponsored Programs J. Craig Venter Institute 9704 Medical Center Drive, 4th Floor Rockville, Maryland 20850 Phone: (240) 268-2755 Fax: (240) 268-4000 Email: xxxxxx@venterinstitute.org Home Page: www.venterinstitute.org -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Brian Anderson Sent: Friday, July 15, 2005 2:30 PM To: xxxxxx@HRINET.ORG Subject: [RESADM-L] Budgeting for Radiation Waste Disposal An issue has come up at my institution regarding the budgetary treatment of chemical waste disposal on grants, particularly radiation waste. Since we don't use these materials very often in research on our campus, the individual costs can easily be isolated and allocated to individual grant projects (seems to meet the allowable, reasonable, allocable test). On the other hand, a faculty collaborator from another institution informed one of our faculty that such costs if direct charged would raise eyebrows because it is normally treated as a component of institutional F&A cost. Do you treat radiation waste disposal as F&A cost and include it in your F&A rate proposal or do you treat it as a direct cost at your institution? I appreciate your comments. ------------------------ Brian Anderson, Director Office of Research Development Eastern Michigan University Starkweather Hall, 2nd Floor Ypsilanti, MI 48197 Office: (734) 487-3090 Fax: (734) 481-0650 Email: xxxxxx@emich.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") ======================================================================