And see NIH FAQs page just updated today:
http://grants.nih.gov/recovery/faqs_recovery.html#If4

*Can ARRA grant budgets include direct costs to address ARRA
administrative and reporting requirements? *(New: 05/15/2009)
No. It has been determined that ARRA requirements do not provide
sufficient justification to support the provision of direct costs for
administrative support in addition to the Facilities and Administrative
(F&A) costs in the awarded budget.

NIH staff will continue to evaluate direct costs requested for
administrate support using the guidance provided in OMB Circular A-21
F.6.b.(2) http://www.whitehouse.gov/omb/circulars/a021/a021.html.
However, ARRA requirements will not be considered in this determination,
because they are incorporated within the core administrative support for
the project, which is reimbursed to the institution through the
provision of F&A costs.

When direct costs have been requested to address ARRA administrative and
reporting requirements in requested budgets, NIH staff will make
appropriate adjustments . Revised budgets submitted solely to remove
administrative costs will not be accepted.

Pamela Plotkin, Ph.D.
Deputy Director, Office of Sponsored Programs
Cornell University
373 Pine Tree Road
East Hill Plaza
Ithaca, NY 14850-2820
607-254-8329
xxxxxx@cornell.edu

Katie Hudson wrote:
> Hey folks,
> I know there's been a lot of talk about using ARRA requirements as a
> justification requesting some administrative expense as a direct cost;
> if you did so with NIH you can probably expect a call from your grants
> management specialist soon.  This just in from a memo circulating at GMS:
>
> Many ARRA budget requests, particularly those submitted
> by universities, have requested administrative costs as a direct cost
> citing the additional administrative and reporting requirements of
> ARRA.   After consideration by Federal costing officials, **it has
> been determined that ARRA requirements alone do not provide sufficient
> justification to support the direct charging of administrative costs.   **
>
>
>
> Accordingly, ICs should continue to apply the guidance provided in OMB
> Circular A-21 to determine if an ARRA project qualifies as a 'major
> project' and, if so, justifies direct charging of administrative
> costs.    However, ARRA requirements are to be excluded  as a
> justification in making this determination, because they are
> considered to be incorporated within the core administrative support  for
>
> the project (and reimbursed to the institution through the provision
> of F&A costs).
>
>
> I actually had my department skip this whole angle, but now NIH is
> giving my legitimately major project extra scrutiny.
> *sigh*
>
> --
>
> Katie Hudson
> Sr. Contracts and Grants Analyst
> Extramural Funds Accounting - Molecular and Cell Biology
> University of California, Berkeley
> 40 Giannini Hall
> 142 LSA, Mail Code # 3200
> Berkeley, CA 94720
> *
> *Phone/voice: 510.642.7299   Fax: 510.642.9937
>
> E-mail:  xxxxxx@berkeley.edu
>
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