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
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