A-21,F.6.b Compliance -Reply Jennifer Morgan 04 Jun 1998 09:36 EST

Eric -

As long as a cost has been included in the budget and adequately
justified as an unusual circumstance; has gone through sponsor review;
and has been awarded as budgeted, you can pay for costs as direct
that are normally treated as indirect.  Of course, the approved budget
and justification should be kept as a back-up document for the
post-award file.

I have some example budget justifications that I developed when I taught
a series of sessions on Direct Costing under CAS to all faculty and
senior administrative staff at the University of Alabama at Birmingham.  I
assume that the justifications are good as I have subsequently learned
that Coopers and Lybrand have freely plagiarized these examples,
merely changing the fictitious names I used in the examples.  (I still
haven't decided whether I am flattered or annoyed about this.)

If you would like a copy of those examples, just let me know.  I'll be
happy to send them to you either by fax or attach to an email as a
WordPerfect document.


Jennifer Morgan
Director of Sponsored Programs
Office of Grants & Contracts
Allegheny Campus
Allegheny Univ. of the Health Sciences
One Allegheny Center, Suite 880
Pittsburgh, Pennsylvania  15212
412-359-1523 (voice)
412-359-1556 (fax)

>>> Eric D Carter <xxxxxx@COMPTROLLER.UMD.EDU> 06/03/98
04:31pm >>>
I am interested to know what procedures other institutions are using to
insure compliance with A-21 particularly section F.6.b regarding
"departmental administration" payroll and other operating costs.

For example, do you include line items in project budgets for
secretarial, clerical, and administrative salaries, telephone (local
charges), office supplies, photocopying costs, and other costs which

"usually" indirect costs in "normal" circumstances.

For those of you doing post-award administration, what procedures do

use to check the appropriateness of "departmental administration" costs
which are charged directly to sponsored projects? Do you compare DA
charges to grants with the project budget?   How much of this A-21
(F.6.b) compliance responsibility resides with the P.I or academic
department and how much resides at the institutional level?  Do you have

written procedures for A-21, F.6.b. compliance?

Thank you,

Eric Carter, Executive Accountant
University of Maryland College Park