The wiggle room is intentional so that each institution can apply their own policies. The main thing is to be consistent. If you charge one grant for something, you have to apply that same type charge to the others. I would suggest that YOU draw up a guideline you would like to apply to your unit, citing Exhibit C, and run it past your primary funding agency and whoever is throwing up the roadblock at your institution. As long as you apply the guideline consistently to all grants AND it's within the broad parameters of what's allowable under Exhibit C, you should be okay as far as the feds are concerned. Whether or not the bureaucrats at your institution will go along with it is another thing. Some folks are insistant on erring way to one side on the side of the stricted interpretation. Of course, they are concerned about auditors, not how you can actually get the scope of work done to include the allowable costs that would normally be treated as F&A. To get past that hurdle, do what you can to soothe their shaky nerves about the auditors... by establishing a written guideline, quoting regs, and then adhering to it consistently. Just a suggestion... -Jennifer >>> xxxxxx@VIRGINIA.EDU 09/23/05 09:10AM >>> Thanks, it is Exhibit C to which I was referring when I asked about interpretation of these guidelines. The examples seem to leave a lot of wriggle room. Approximately 1/3 of our funding comes from a single federal contract, but the rest of our funding comes from about 30 -40 different contracts of varying sizes and from varying sources - both federal and industry. We do charge the off-campus F&A rate. I was hoping another institution had a similarly structured off-campus research center that has faced this issue. Linda _____ From: Youngers, Jane A [mailto:xxxxxx@uthscsa.edu] Sent: Thursday, September 22, 2005 5:26 PM To: xxxxxx@virginia.edu Subject: RE: [RESADM-L] off campus research centers Linda, Terri is correct. But the other issue is one of allocability; if your center has many awards, it would be very hard to allocate administrative salaries among them all. It's different if there were one or two. So your OSP may be bringing up allocation issues. Just a thought. Jane Jane A. Youngers Assistant Vice President for Research Office of Sponsored Programs The University of Texas Health Science Center at San Antonio 7703 Floyd Curl Drive San Antonio TX 78229-3900 telephone 210.567.2333 fax 210.567.2344 xxxxxx@uthscsa.edu -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Terri Hall Sent: Thursday, September 22, 2005 3:51 PM To: xxxxxx@HRINET.ORG Subject: Re: [RESADM-L] off campus research centers Linda, See A-21's Section J - Exhibit C for examples when "direct charging of administrative or clerical staff salaries may be appropriate." Terri Terri M. Hall Associate Director of Sponsored Programs (eRA) Office of Research * University of Notre Dame 511 Main Building * Notre Dame, Indiana 46556 Phn: (574) 631-7378 Fax: (574) 631-6630 http://www.nd.edu/~research/ ~ an FDP institution ~ ----- Original Message ----- From: Linda Callihan <mailto:xxxxxx@VIRGINIA.EDU> To: xxxxxx@HRINET.ORG Sent: Thursday, September 22, 2005 2:06 PM Subject: [RESADM-L] off campus research centers Does anyone have any insight into or experience with interpreting the guidelines in OMB Circular A-21 on exceptions to the CAS regulations for charging administrative personnel as direct costs when the research is conducted at an off-campus facility? I know that sounds like a mouthful, but I'm getting conflicting messages from our Office of Sponsored Programs on this and am wondering if other institutions have similar research centers at off campus locations and they are able to support administrative staff from their federal research grants and contracts. Thanks, Linda Linda H. Callihan Center for Applied Biomechanics University of Virginia 1011 Linden Ave Charlottesville, VA 22902-6241 ph: 434 296-7288 ext. 142 fax: 434 296-3453 <mailto:xxxxxx@virginia.edu> xxxxxx@virginia.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") ====================================================================== ====================================================================== 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") ======================================================================
