Hi-

The majority here feel that full itemized budgets must be required and
obtained in-house at the time of NIH application submissions under the
modular system.  Yet, I have heard some suggest that they will make the
full budget optional provided that salary info and indirect cost
calculation tables ARE provided prior to submission.

Aside from the issues surrounding indirect costs, there must be 2
interpretations of what is required to meet cost accounting standards with
respect to pre-award responsibilities.

The sections from OMB Circular A-21 shown below seem to offer some
interpretative space with respect to consistency in estimating,
accumulating and reporting costs.  Whether unallowable costs underlying but
not actually revealed in a "submitted" modular budget constitute a
violation seems more of a problem.

C. 10. c.   The grouping of homogeneous costs in estimates prepared for
proposal purposes shall not per se be deemed an inconsistent application of
cost accounting practices under subsection a when such costs are
accumulated and reported in greater detail on an actual cost basis during
performance of the sponsored agreement.

Appendix A
CAS 9905.501
The standard does not prescribe the amount of detail required in
accumulating and reporting costs. The basic requirement which must be met,
however, is that for any significant amount of estimated cost, the
sponsored agreement must be able to accumulate and report actual cost at a
level which permits sufficient and meaningful comparison with its
estimates. The amount of detail required may vary considerably depending on
how the proposed costs were estimated, the data presented in justification
or lack thereof, and the significance of each situation. Accordingly, it is
neither appropriate nor practical to prescribe a single set of accounting
practices which would be consistent in all situations with the practices of
estimating costs. Therefore, the amount of accounting and statistical
detail to be required and maintained in accounting for estimated costs has
been and continues to be a matter to be decided by Government procurement
authorities on the basis of the individual facts and circumstances.

CAS 9905.505
Costs expressly unallowable or mutually agreed to be unallowable, including
costs mutually agreed to be unallowable directly associated costs, shall be
identified and excluded from any billing, claim, application, or proposal
applicable to a Government sponsored agreement.

Charlie Hathaway

**************************************
Charles B. Hathaway, Ph.D., Director
Office of Grant Support
908A Belfer
Albert Einstein College of Medicine
1300 Morris Park Avenue
Bronx, NY 10461
Phone: 718 430-3642     Fax: 718 430-8822
email: xxxxxx@aecom.yu.edu
http://www.aecom.yu.edu/ogs

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