This page includes answers to questions about:

• Effective date and applicability to proposals/awards- 2 questions
  
  
• Charging administratively intensive activities directly to awards - 4 questions
  
  
• Major vs. Non-major Projects - 2 questions
  
  
• Charging administrative costs used for technical purposes - 7 questions
  
  
• Cost sharing of administrative costs that are
  specifically disapproved by the sponsor - 5 questions

Effective Date and Applicability To Proposals/Awards

1. The revised policy on charging administrative and technical expenses is effective for awards proposed on or after December 1, 1999. Is it applicable to:

   a) continuation proposals?	YES
   b) proposals for supplements?	YES
   c) incremental funding?	NO
   d) no-cost extensions?	NO

   When obtaining new funding, you have an opportunity to request funding for previously unanticipated administrative expenses that you expect to incur on the project in the future.
   
   See applicability of prior versions of the policy (in the box on Implementation Guidelines home page).

   
   
   
2. I have a non-federal sponsored project that requires administrative effort and supplies. Do I need to meet all of the policy criteria in order to charge them as direct costs to the project?

   No, you do not need to meet all the policy criteria to charge administrative costs directly to non-federal awards. The policy is applicable to federally sponsored awards and only to non-federal awards when the non-federal sponsor:

   • receives federal funding for the project, or
   • specifically adopts A-21 guidelines, or
   • has its own policies restricting administrative charges.

   The costs must still be specifically identified to and benefit the project.

Charging Administratively Intensive Activities Directly To Awards

3. If my project qualifies as major, can I charge all of the administration related to that project as a direct cost?

   No. Even if your project is major you can't assume that all of your administration can be charged direct. You can only charge all of a project's administrative costs as direct costs when:

   • all project-related administration pertains directly to the activities that make the project major (project-related administration is extensive and beyond the routine level), or
   • the project is complex (as described in A-21 example #1), or
   • the project is geographically inaccessible (as described in A-21 example #5), or
   • the project requires multiple project-related investigator coordination and communications (as described in A-21 example #6).

4. I have a small project that is less than $100K for salaries and supplies only. The project requires someone to process and track complex human subject protocols. Can I charge administrative effort to this project?

   You may charge the human subject protocols administration directly to your project if that activity is intensive and all other policy criteria have been met (specifically identified to and benefit the project, included and justified in the budget, and not specifically disapproved by the sponsor). There may be other project activities that would warrant direct charging of administrative expenses.

5. What if I have a project that includes coordinating a conference for many participants, but includes research administration for the rest of the project as well. Can I charge all of the administration as a direct cost?

   No. Unless the research administration is administratively intensive, only the administration related to coordinating the conference is allowable as a direct charge. You need to consider the project's other administrative activities using the examples listed in the policy and these guidelines to determine whether they can be charged direct.

6. Can I charge all of my project-related administration if I have a conference grant that I am administering?

   Yes, as long as all of the administration is related to coordinating that conference grant.

Major vs. Non-Major Projects

7. One of the projects in my department is to develop an electronic encyclopedia on a web site that will be maintained on an on-going basis. Do you think this would classify as a major project? Some of the activities that seem administratively intensive are communication with and coordination of several board members and many contributing authors, managing their computer accounts and entries, providing HTML support to the authors, literature retrieval, word processing input, and maintaining the web site.

   Yes, your project is a major project under A-21 example 4 (see examples) whose primary focus is the preparation and production of manuals and large reports, books and monographs. The activities you mention make this project administratively burdensome and therefore major. All of the administrative activities that are intensive can be charged direct.

8. I have a project in the Medical School that uses animal subjects. According to the definition of major, a project with human or animal protocols is considered a major project. I am not sure whether my project is administratively intensive because the research associate assigned to the project, not an administrator, manages all the work associated with the animal protocols. Is my project major?

   Even though OMB Circular A-21 and Stanford's policy lists projects with animal or human subject protocols as projects that may be major, the project must also be administratively intensive in order to classify as a major project. In your case, the research associate who is conducting the animal protocols and applying their technical expertise to the procedure is already being charged directly to the project. The fact that your project requires animal protocols does not make it administratively intensive, and therefore does not make your project major. However, if an administrator conducts the animal protocol activities and you consider that effort to be administratively intensive, your project may be major. There may be other conditions, as listed in Section V above, that may make your project major and related administrative costs that may be charged direct.

Charging Administrative Costs Used For Technical Purposes

9. Does the project have to be considered "major" in order to charge publication costs?

   No. Federal awards require the PI to publish the results of federally funded projects. Therefore, this is an example of an administrative charge used for the technical purpose of the project and the "major" criteria does not have to be met.

10. If a project is not administratively intensive, and therefore not major, what types of costs can be charged directly to a sponsored project? For example, for my project we must mail time-sensitive samples using an overnight delivery service. The samples must be delivered before they deteriorate. Can I charge these costs to my sponsored project?

    In the example you have cited the costs are for the project's scope of work, rather than for the administration of the project, and can be charged as direct costs as long as they can be specifically identified to and benefit the project, are included and justified in the budget, and are not specifically disapproved by the sponsor.

11. Can I charge the costs of photocopying research papers and making transparencies for use in technical meetings to my sponsored project?

    Since these costs pertain to the scope of work of the project, you can charge them as direct costs as long as they can be specifically identified to and benefit the project, are included and justified in the budget, and are not specifically disapproved by the sponsor.

12. I administer the sponsored projects in the Computer Science Department. Computer costs are listed in the policy as technical costs. Does this definition also include computer-related items such as computer networking cables, and toner and paper for the printer? If so, can the cost of these items be charged to a non-major project?

    In the Computer Science Department, your laboratory equipment includes your computers. It is reasonable to charge toner, paper, networking cables and other computer-related items as direct costs as long as they can be specifically identified to and benefit the project, are included and justified in the budget, are not specifically disapproved by the sponsor, and you are not using the computers for routine departmental administrative work. If the computers are being used for routine administrative work for your department as well as technical purposes, the time spent on routine administration must be tracked and the costs charged to a departmental operating or other account. If the administration directly benefits the project and meets the criteria of the policy, the cost can be charged to the project. If the user devotes 100% effort to the research project, the total computer-related cost should be charged to the project.
    
    This scenario may also apply to projects in other departments that use computers for data analysis, statistical sampling, mathematical modeling, etc.

13. I administer several non-major projects. Can I charge the copying and postage charges for the interim and final reports directly to the projects?

    Copying and postage charges may be incurred as general departmental administrative costs, but in this case the costs pertain to technical reports, which are explicit programmatic requirements of the sponsored project and should be charged directly to the award. It is part of the performance of the scope of work of the project and the way the research results are communicated to the sponsor, colleagues, and collaborators. A budget justification for this category of costs is required. GL code 94630 "Report Costs" should be used when charging these expenses.

14. Several months after my project was awarded I needed to do some technical work that required use of some items that are normally administrative. What must I do in order to be able to charge these costs directly to my project? I did not anticipate these costs so they are not in my proposal.

    If your sponsor is NIH, or another sponsor that allows specific rebudgeting authority for administrative expenses, you can use that authority to charge administrative expenses. If your sponsor does not allow rebudgeting authority for administrative expenses you must supply a budget justification and obtain sponsor approval.

15. I have a contract where human subjects interviews are part of the project's scope of work. The PI forgot to include a line item for transcription services and did not document the project as major. The project requires that the interviews be transcribed. Does the PI need to inform the sponsor that the project is major and request rebudgeting approval?

    When the transcription service is intensive in nature and in sole support of the project's scope of work, it should be charged as a direct cost after providing the sponsor with the necessary documentation, including justification, to obtain their approval. This is the type of activity that would fall under major project example #6. Transcription services are the kind of activity that may be considered administrative or technical depending on the purpose of the activity. If the transcription service is in support of normal departmental activities, then the cost is administrative and should not be charged as a direct cost to the grant.

Cost Sharing of Administrative Costs That Are Specifically Disapproved by the Sponsor

16. In my original budget, I included an administrator at 50%FTE to coordinate survey participants and enter the survey data into a database. The sponsor specifically disapproved the cost, but did not reduce the scope of work. To deal with the lack of funding for the administrator, I will reduce the number of survey participants. Instead of using the administrator at 50% FTE, I will only use him at 25% FTE. Do I need to cost share the full amount that I proposed, or only the 25% FTE that I will incur to support the project?

    You only need to cost share the actual amount incurred to support the project. Sometimes when there is a budget reduction and the overall scope of work is not reduced, some of the specific aims of the research (e.g. number of tests, number of participants, number of surveys) may be reduced.

17. I originally proposed an administrator to record the results of some testing that was to be done on my project. The sponsor specifically disapproved the cost of the administrator, but did not reduce the scope of work. During the course of conducting the research, I was able to reach a scientific conclusion without performing the tests that I had originally anticipated and that would have been tabulated by the proposed administrator. Do I still need to account for cost sharing?

    No, since the tests did not need to be performed, no costs were incurred, and therefore there are no costs to cost share. It is understood that the originally anticipated scope of work may be affected by the course of the science and that the administrative work may not need to be performed or may be performed at a lower cost than originally proposed.

18. My PI proposed administrative support to handle all the human subject protocols for a project. The sponsor did not approve the budget for the administrator, but did not reduce the scope of work. Our department does not have the additional funds to support the cost of the administrator, and since the human subject protocols still need to be done, my PI assigned it to a research associate with a 50% appointment on the same project. The research associate is not paid overtime and will need to put in more time to perform this function in addition to his other tasks on the project. Do I account for this additional effort as cost sharing?

    Since there is no additional cost to the University, there is no cost to be cost shared.

19. I budgeted an administrator on my NIH Program Project at 30%. We received the award with an overall budget cut with a corresponding reduction in the scope of work. If I reduce the administrator to 25% because of the budget cut, do I need to cost-share the difference?

    If the administrator's effort on the project is only 25%, you do not have to cost share. However, if the administrator expends 30% effort on the project you must cost share the 5% difference.

20. The revised Administrative Charging Policy states that administrative costs that are specifically disapproved by the sponsor must be accounted for as cost sharing, yet the Cost Sharing Policy states that unallowable costs cannot be offered as cost sharing. Does that mean that specifically disapproved administrative costs cannot be used to fulfill a cost sharing commitment?

    Administrative costs specifically disapproved by a sponsor wouldn't be offered as cost sharing because one wouldn't know at the time of proposal submission that they were going to be disapproved. They can however be used to fulfill a commitment once it comes time to report back to the sponsor on cost sharing. The Cost Sharing Policy states that unallowable costs per A-21, section J. are not eligible for cost sharing; however, administrative costs that are disapproved by a sponsor are not unallowable costs. By disapproving the costs the sponsor is simply indicating that they will not pay for those costs.