UCSF COST ACCOUNTING STANDARDS (CAS) GUIDELINES (Charging Practices for Sponsored Projects)

APPENDIX B:  Frequently Asked Questions (FAQs)

Departments are welcome to submit questions to get additional clarification of these FAQs.  As appropriate, the FAQs will be updated so that all departments may benefit from the clarifications or additional information. Inquiries and suggestions should be directed to Charles Taylor (ctaylor@finance.ucsf.edu) or Matt Suelzle (msuelzle@finance.ucsf.edu) in Budget and Resource Management.
TABLE OF CONTENTS

Clarification of Terms Used in the UCSF Charging Practices for Sponsored Projects document
Responsibility
Types of Grants Affected
Proposal Preparation
Functional Categorization and Department Administration
Salaries, Wages, Benefits, and Effort
Office Supplies
Printing, Publications, Photocopying, and Photocopiers
Postage and Mailing
Telephones
Subscriptions
Repairs, Maintenance, and Janitorial
Leased Space
Subcontracts and Subrecipients
Other Specific Kinds of Expenditures
Cost Overruns
Miscellaneous Questions

Clarification of Terms Used in the UCSF Cost Accounting Standards Guidelines (CAS), Charging Practices for Sponsored Projects document:

1) Under "Guidelines for Direct-Charging Administrative Costs to Federal Projects, Treatment of Administrative Salaries and Benefits on Extramural Funds, Standard Treatment (section IV, A, 1) UCSF CAS Guidelines," please explain the following, with examples:

Responsibility

1) Who has the final responsibility to ensure that the charging guidelines are followed?

Answer: The Principal Investigator has final responsibility for all charges appearing on his or her funds.

2) Does UCSF have to be consistent even if the funding agencies are not?

Answer: Yes. Cost Accounting Standards (CAS) guidelines apply to all federal funds (including federal flow-through funds). CAS authority is delegated to the campus.  The federal government does not override campus CAS guidelines.   If the award is more restrictive than UCSF CAS guidelines, then follow the terms of the award.  If the award is less restrictive than UCSF CAS guidelines, then follow CAS guidelines.  For example, an R01 proposal budget may have included an administrative assistant for routine administrative duties.  Under UCSF CAS guidelines, this is an administrative expense and may not be charged to the R01, even if the award notice appears to allow it.

Types of Grants Affected

1) Are General Clinical Research Center (GCRC) and Pediatric Clinical Research Center (PCRC) awards exempt from UCSF CAS guidelines?

Answer: Yes, with regard to administrative costs. The F&A rate negotiated for the GCRC and the PCRC awards adjusts for Department Administration costs charged directly to these grants. Therefore, Department Administration costs should be direct charged.   All other aspects of UCSF CAS guidelines apply to these grants.  Note that federal funding for GCRCs and PCRC are now included within the larger Clinical and Translational Science Initiative (CTSI) award.

2) Do the UCSF CAS guidelines apply to users of a CRC (Clinical Research Center) who are separately funded?

Answer: Yes.  Users of any CRC who are funded outside of the GCRC or PCRC awards themselves are under the UCSF CAS guidelines, if they receive full or partial funding from any federal awards.

3) What types of grants are subject to the cost accounting standard charging practices? R37s? PPGs? Center grants?

Answer: The UCSF CAS guidelines apply to ALL federal contracts and grants. This category includes contracts/grants from state, county, city, or private sponsors, which are fully or partially funded by the federal government (i.e. "federal flow-through awards").

4) Could further guidance be given on Program Project Grants (PPGs) and other federal multi-project grants clarifying what is allowable and unallowable as direct charges under CAS?

Answer: Routine administrative activities are not allowable as direct charges to federal grants, including PPGs and other multi-project grants.  Routine administration includes the following actions: preparation of grant/contract proposals; personnel related activities such as preparation of PAFs, inputting changes to OLPPS, and hiring actions; routine purchasing; general ledger review; and preparing cost transfers. 

However, non-routine administrative activities for awards that require extensive administrative support (such as PPGs and other multi-project awards) are allowable. Examples of expenses that would be allowable on these types of projects include the following:

5) Are training grants subject to UCSF CAS guidelines?

Answer: Yes.  If they are federally funded, training grants are subject to UCSF CAS guidelines. Also, the funds awarded as training related expenses in many federal training grants must be spent in accordance with UCSF CAS guidelines. However, charging certain kinds of administrative support costs to training grants is often allowable because the nature of the program requires coordination of trainees and the related paperwork, which is beyond the routine. For example, an administrative assistant who is responsible for completing the trainee appointment forms, coordinates the fellowship recruitment and selection process, and maintains the database of past and current fellows in the program may have the corresponding effort directly charged to the training grant.
Additionally, all training grants, regardless of funding source, should use an instruction DPA (e.g. 40xxxx) attached to the fund, not a research DPA (e.g. 44xxxx).  For further clarification, contact Jim Reiter, Controller’s Office, General Accounting, 502-3004 (jreiter@accounting.ucsf.edu).  Also, see NIH Grants Policy Statement on Training Grants  and UCSF Controller's Office Guidelines on DPAs.

6) Do UCSF CAS guidelines apply to federal flow-through funds where the federal government does not pay any overhead?

Answer:  Yes, UCSF CAS guidelines do apply.  To date, the federal government has not indicated any exception to CAS compliance for grants or contracts that do not pay overhead.

7) Do UCSF CAS guidelines apply to municipal (i.e. city or county) and State of California contracts? If such a municipal or state awards were funded from a Federal Block Grant, would UCSF CAS guidelines still apply?

Answer: Yes and no.  OMB Circular A-21 and CAS principles do apply to municipal (i.e. city or county) and State of California contracts if they include, in full or in part, any funds from the federal government (i.e. federal flow-through funds). However, both the U.S. Department of Health and Human Services and the California Department of Public Health have stated that OMB Circular A-21 and CAS principles do not apply to Federal Block Grant/Funds type programs. At the time of proposal preparation, departments should work with UCSF's Contracts & Grants Office to make an accurate determination as to whether or not: 1) a city or state sponsored project is federally funded, and 2) if the project is funded under a Federal Block Grant/Funds program.

8) May “CAS–disallowed” expenses, such as General, Automobile, and Employee Liability (GAEL), be charged to partial federal flow-through funds like JPAs and some municipal contracts?

Answer:  No. GAEL is disallowed because charges cannot be changed from F&A to direct charges. In 1991, the US Office of Management and Budget (OMB) revised OMB Circular A-21 to prohibit unapproved changes of F&A costs to direct costs.  At that time, GAEL was paid by UCOP and included as an F&A cost to each campus.  Later, the cost was passed directly to the campus.  The campus direct charges awards for GAEL whenever possible.  However, because GAEL was an F&A cost in 1992, it must remain so and may not be charged to any award with federal funding.

Proposal Preparation

1) What level of detail must be included in budget justifications? Must allowable costs be detailed out?

Answer: Detail must be sufficient to enable reviewers to determine whether the costs are reasonable and allowable for conduct of the project. All justifications for costs that may appear to be administrative in nature, such as postage, telephones, etc., must show that they can be specifically allocated to the project and are required specifically for the project to meet its aims so that reviewers do not perceive them to be routine and cut funding for them.  For example, the purchase of CD-ROMs that are sent to multiple sites for data to be recorded and sent back to the coordinating center is an allowable cost.  The purchase of paper for a shared copier, some of which will be used for the project but most of which will be used by the administrative office is NOT an allowable cost.
Also, it is best to provide detail in the descriptions and narratives of the budget, but not to actually specify the dollar amount of costs to such a detailed level.

2) May modular grants include items disallowed under the UCSF CAS guidelines since the NIH does not require a detailed description of the budget?

Answer:  No.  Expenses must be allocated and accounted for in accordance with applicable cost accounting principles and the NIH Grants Policy Statement.
 Functional Categorization and Department Administration

1) Should departments have a number of different DPAs linked to 19900, Pro Fee and Prior Year's funds -- one of each for Department Administration, Instruction, Research (cost shared portion), and Patient/Clinical Care?

Answer:  Probably.  It is possible to have many DPA-fund linkages, depending on the specific circumstances, needs, and choices of the department. The objective is consistency in identifying costs incurred by function, regardless of fund source. For those departments electing to specifically identify department administration via DPA(s), those DPA(s) can be linked with any appropriate non-federal funds.   See Controller’s Office website for further clarification on DPAs.   UCSF Controller's Office Guidelines on DPAs.

Salaries, Wages, Benefits, and Effort

1) Campus guidance directs that averaged or actual fringe benefits may be used in proposal preparation. How is consistency achieved in proposal preparation?

Answer: UCSF CAS guidelines, federal agencies, and campus policy allow for benefit costs based on an average rate to be used in proposal budgets, but the charges are actual benefit costs incurred.  For budget consistency, use salary escalation and benefit rates provided by the Office of Sponsored Research. It is generally acceptable under UCSF CAS guidelines to accumulate costs in more detail than they are estimated (i.e. charge costs in greater detail than budgeted). Using an average benefits rate to estimate costs, but then charging actual benefits is an example of this principle. However, it is not acceptable under UCSF CAS guidelines to budget costs in more detail than they are accumulated.

2) If I submit a budget proposal at the highest salary cap allowed even though the PI is currently at a much lower salary rate, may the PI be paid the higher salary cap rate if the award is made at the full rate?

Answer:  No.  Departments should submit budgets prepared using the actual salary cost, plus estimated merit increases as described in the salary and benefits guidance memo issued by the Office of Sponsored Research. It is fraudulent to request salary rates higher than those allowed by University compensation policies, or to allow a PI or staff to be paid a higher salary rate on the basis that the award provided funding at the higher rate.

3) How should voluntary and mandatory cost sharing be handled?  

Answer:  Please refer to the UCSF Cost Sharing Campus Administrative Policy 400-17 and UCSF Controller's Office Procedures on Cost Sharing for more information.

4) If cost shared effort is associated with a grant, are fringe benefit charges allowed to the grant up to the percent of the cost shared effort?

Answer:  No. Fringe benefits must be charged to the fund that pays the salary.

5) How is Effort Reporting related to CAS? How should cost sharing effort be reported?

Answer: Effort reporting is used to report and certify paid and unpaid effort.   Cost sharing effort is captured on an effort report. Certified effort reports are UC's method of documenting the distribution of personnel services as required by OMB Circular A-21, section J.10.b.  See UCSF CAS guidelines, Section VIl Effort Reporting and the UCSF Controller's Office website on Effort Reporting.

6) Research assistants whose duties directly benefit sponsored research have job titles "(blank)" Assistant. I, II, and III because this is how Human Resources has classified these positions. Will new title codes be made available to differentiate legitimate direct activities for sponsored research?

Answer: We are not aware of any current plans to create new title codes due to CAS. If the duties of these "(blank)" Assistant I, II, or IIIs benefit the "science of the project" and can be substantiated, then their efforts devoted to the project may be direct charged to the project. Such efforts directly benefiting the science of the project should be explained in the project proposal.

7) How should departments handle the minor administrative duties that a Staff Research Associate (SRA) performs?

Answer: When an employee devotes minimal effort to a single function (including administration) which is considered immaterial, it is not necessary to separately identify it. There is no governmental, University, nor campus policy on what constitutes "minimal effort." As a guideline, this is generally no more than 5% FTE. This 5% guideline is an aggregate amount -- e.g. if the person devotes 3% administrative effort each to projects A, B, C, D, E and F, the total amount of administrative effort for the person is 18% which is probably material. Particular circumstances in individual cases may suggest a different threshold is appropriate.

8) Are invoice reviews an administration activity? What about reviews of subcontract invoices?

Answer: Yes, invoice review is an administration activity and should be charged as such. Where there is extensive review of invoices (or any other type of normally administrative activity) for subcontracts due to the nature of the arrangement, such costs should be direct charged. For example, an analyst who must review the invoices from multiple national and international institutions for one project could have the corresponding effort directly charged to the award.  Also, see the question 7 in this section for a discussion on "minimal efforts" devoted to administrative duties.

9) Is an Administrative Assistant II's time devoted to the paperwork surrounding traveling (e.g. advances, reimbursement, etc) “routine" administration?

Answer: No.  Under current UCSF CAS guidelines, travel costs are considered beyond the routine and, therefore, should be direct charged to the appropriate benefiting activity or activities under CAS. This includes the costs of arranging and processing the travel. So to the extent the travel is allowed by the award and benefits the science of a project, the appropriate portion of the travel costs and of travel arrangement/processing costs should be directly charged to the project. One reason that such arrangement/processing costs might not be charged to an R01 or other grant is that the amounts are minimal, which is an aggregate of 5% or less during the budget period. (See question 7 in this section for guidelines on minimal effort.)

Office Supplies

1) May you budget for routine office supplies in a grant proposal?

Answer: No. Routine office supplies such as pens, binders, copier paper, filing folders and bins, software licenses that can be used for other purposes (e.g. MS Office) are considered department administrative costs and should neither be budgeted nor charged to federal funds. Administrative supplies that may seem necessary for the operation of a laboratory or research site such as clocks, wastebaskets, and an erasure board should also not be budgeted nor charged to federal funds.  Office supplies that are used for a scientific purpose, like lab notebooks, graph paper, etc. may be direct charged to federal grants.

2) May non-federal funds be charged for office supplies if it is within sponsor guidelines?

Answer: Yes. While office supplies used for routine administrative activities are not to be charged to federally funded projects, sponsored project funds from private sources or state and local governments (except for federal flow-through awards) may still be direct charged for this expense. The federal government approved UCSF’s Disclosure Statement, in which UCSF's policy of different treatment between federal and non-federal sponsors was disclosed. 

Printing, Publications, Photocopying, and Photocopiers

1) May departments charge photocopy expenses to federal grants?

Answer: No. Recharges to federal funds for routine photocopying should be redirected and charged as department administration. However, recharges for justified photocopying for the scientific aim of the project, such as brochures required for subject recruitment or questionnaires, should always be charged directly to the benefiting activity, even if that activity is a federally funded project.

2) Are photocopies of journal articles an allowable expense on federal awards?

Answer:  Maybe.  Photocopies of journal articles are an allowable expense when they are directly related to meeting the specific aims of the research project.  For example, copies of journal articles used for the purposes of referring to other methodologies, reference articles, and/or findings on similar hypotheses can contribute to the conduct of the research.
Photocopies of articles for general purposes that are not directly related to meeting the specific aims of the project are not allowed on federal funds.  For example, copies for a journal are not allowable since they are considered an F&A cost and should be charged as department administration.

3) How should we treat the costs associated with copying human subject certification forms?

Answer: Copying human subject certification forms is program specific and should be direct charged to the project. It is also important that all projects with human subject certifications be treated consistently. So, for example, a privately funded clinical trial benefiting from human subject certifications should be direct charged all appropriate costs, including costs of copying the certification forms.

4) How should departments treat the costs associated with the preparation of publications? May office supplies used for the publications be direct charged to the project? May the photocopy and office supply costs associated with surveys (e.g. epidemiological surveys) be direct charged to the project?

Answer: Yes. Costs related to the preparation of publications, including the office supplies used, should be direct charged to the project. Costs associated with a survey that is part of the project should be direct charged.

Postage and Mailing

1) Is the cost of mailing reprints allowable?

Answer:  Sometimes. 

Telephones

1) If one phone set in each lab is labeled "For Research Only" and is used only for sponsored research, may we charge the line charges, local and long distance calls on this phone to research?

Answer: No.  Local calls, line charges, and phone equipment costs are not normally allowable on research awards under the Cost Accounting Standards, although long distance charges are allowable.  An exception to this rule is the case of a sponsored project award where a phone line is required in order to perform a specific project function such as phone interviews with study subjects, or to monitor study patients.  In this case, it is allowable to set up one particular phone dedicated solely to the one research project and then charge the full cost of the scientifically related telephone charges to that one award.

2) We are currently charging telephone charges to our pro fees and charging federally sponsored projects for applicable long distance phone charges. Is this acceptable?

Answer: Yes.  This is acceptable. The local call, line, and equipment charges should be charged as Department Administration.

3) If someone makes a personal call from a telephone line that is paid for by a federal source, may the person reimburse the university by making a deposit to a federal grant or would we need to move any personal call charges to an unrestricted fund and then reimburse that fund?

Answer:  Yes to the first option, no to the second.  The University discourages the use of University telephones for personal calls.  However, if someone makes a personal phone call, the reimbursement for that personal phone call should be posted to the same NCA-DPA-Fund as where the phone expense resides. This could be a federal fund.

4) Is the purchase of a cell phone and related monthly charges allowed on a federal award?  What about a Personal Digital Assistant (PDA) device such as a Blackberry, iPhone, Palm, etc.?

Answer:  Maybe. The purchase of a cell phone or PDA and associated monthly fees is allowable on a federal award only if it is required for direct performance of a project.  For example, if a PI needs to check in hourly on the status of patients participating in a federally funded clinical trial project, and the PI is frequently away from phone access (e.g. traveling between hospitals), then a charge of this type would be allowable.  This direct charge must also comply with the reasonableness principle – as must any direct charge to a federal award.  Use of a cell phone or PDA that is direct charged should be limited to the project from which it was purchased and should not be used for non-award related purposes.

Subscriptions

1) May a subscription be charged to a sponsored project if it benefits the specific project and several other projects, as well? Do we have to divide the cost among projects?

Answer: No. You should charge only the first project identified. Subscriptions may be charged to a sponsored project if the periodical is not in the library and if it benefits the specific project.

2) Do the charging guidelines regarding subscriptions apply to off-campus facilities (e.g., Fresno, China Basin)? 

Answer: Yes.  The subscription guidelines apply to off-campus facilities. An exception is made with regard to the "if the periodical is not in the library" rule for off-campus facilities that are out of the area. For this purpose, "out of the area" means the facility is one outside of San Francisco and northern San Mateo counties (north of Interstate 380).   Please note that the Medical Education and Research Center (MERC) library at UCSF Fresno is considered an “on-campus” facility.

3) Are books for trainees allowed on a training grant even though a single copy may be found in the library?

Answer: Yes. The trainee allowance under a training grant may be spent on anything related to the training. It would be permissible to buy such books out of the allowance, provided they significantly benefit the training covered by the grant.

4) Membership to a particular professional association includes a subscription to a professional journal that is not in the UCSF library. May I charge the membership cost (that includes the journal) to the grant in order to subscribe to the journal?

Answer: Maybe. The cost of a membership is always an F&A cost (e.g. Department Administration), and should not be charged directly to a federal grant. Subscriptions may be a direct cost provided the journal is not available in the campus library and that the journal benefits the scientific aims of project. If the journal is available in the campus library, then the cost is an F&A one.
To the extent that it is possible to reasonably separate the cost of the membership vs. the cost of the subscription, the two costs should be charged differently in accordance with the UCSF CAS guidelines. If it is not possible to reasonably separate the membership and subscription costs, then the entire amount should be treated as a membership. The best way to document the separate costs would be via written documentation supplied by the professional association.

Repairs, Maintenance, and Janitorial

1) May we establish a recharge methodology to recharge grants for a repair and maintenance contract on equipment, such as sophisticated computer and electronic equipment whose use is solely to benefit research, but which benefits a number of different sponsored projects?

Answer: Yes. See UCSF Policy 250-11 Recharge Activities & Common Cost Allocations and the Budget and Resource Management recharge website for information on establishing a recharge.

2) Does "special needs cleaning" include extra lab cleanings for patients with asthma or other conditions?

Answer: If the project involves patients with a particular condition, such as asthma, and the laboratory's condition is such that it requires special cleaning for the benefit of these patients, the cost of the special cleaning is program specific and therefore should be direct charged.

Leased Space

1) How do we recharge lease, rental, and utility costs among grants that share rented/lease space?

Answer: Departments must use a recharge methodology approved by the campus Budget and Resource Management department. Using the ratio of square footage is almost always an acceptable methodology. Other methodologies will be considered on a case by case basis.   For leased space off-campus, all operation and maintenance costs must be covered by the recharge under full costing policy.  See UCSF Policy 250-11 Recharge Activities & Common Cost Allocations and the Budget and Resource Management recharge website for more information.                

Subcontracts and Subrecipients

1) What are department responsibilities in regard to monitoring budget proposals of subcontracts under federal projects? Specifically, if an unallowable CAS item appears on a subcontract budget proposal, how should the department respond?

Answer: Under OMB Circular A-21, the prime recipient (the University in this case) is responsible for adequately monitoring sub-recipient compliance with federal rules in the applicable circumstances. Applicable CAS rules will apply to subcontract awards under any one of the following circumstances: (1) the subcontract is to an institution of higher education that is under  OMB Circular A-21, (2) if the prime agreement at UCSF is a federal contract containing the appropriate CAS-related Federal Acquisition Regulations (FAR), or equivalent clause, or (3) if the subcontract is for $500,000 or more.
In any of these cases, a department should review the subcontract budget for CAS compliance. If the department has a question about any budget items, they should inform the subcontracting entity that they believe there is a potential CAS problem. Resolution will be either: 1) the subcontracting entity modifies the budget, or 2) the subcontracting entity provides the department with a written statement that the budget was prepared in compliance with federal costing policies applicable to the subcontracting entity. It is important to note that the applicable federal costing policies vary by the type of entity -- university, other non-profit, or for profit (see following question).

2) What are the applicable federal costing policies subcontractors should follow?

Answer: The applicable federal costing policies depend on the type of organization the subcontractor is. Generally they will be as follows:
For Universities or Colleges -- Office of Management and Budget Circular
A-21 (formally Title 2 Code of Federal Regulations Part 220)

For Hospitals -- Department of Health and Human Services OASC-3 Appendix E (formally Title 45 Code of Federal Regulations Part 74)

For State or Local Governments -- Office of Management and Budget Circular
A-87 (formally Title 2 Code of Federal Regulations Part 225)

For Other Non-Profit Entities -- Office of Management and Budget Circular
A-122 (formally Title 2 Code of Federal Regulations Part 230)

For For-Profit Entities -- Federal Acquisition Regulations (FARs)

3) We currently have a subcontract (federally funded) with a non-profit as the prime that does not meet the threshold dollar requirements of $500,000 for CAS. The prime organization is not under the CAS requirements. Does this mean that CAS requirements do not apply to UCSF as the subcontractor?

Answer: No. UCSF is under CAS requirements for this subcontract as the CAS rules apply to all federal flow-through funds received at UCSF.

4) What are the guidelines and responsibilities for detailed management of subcontracts under our federal grants? Since the invoices have only the broad categories of expenditure, we do not see detail and do not know if compliance with CAS is being fully maintained.

Answer: When working with subcontracts under prime UCSF contracts and grants, departments should focus on proposal submission as the time to review subcontracts for compliance with CAS. As invoices do not necessarily contain detailed line items, it is not always possible for departments to view individual charges or items that might raise a CAS concern. However, departments should continue their usual review for compliance with applicable federal grant rules and regulations. Currently, subcontracts issued by UCSF contain language requiring the recipient to comply with federal rules, including CAS. The Principal Investigator is ultimately responsible for post award management of the subcontracts.

Other Specific Kinds of Expenditures

1) Are recharges for the disposal of biohazardous waste which directly benefit a specific research project considered allowable on federal funds under CAS?

Answer: Yes. At UCSF, the cost of any hazardous waste disposal should be direct charged to the activity producing the waste, including federally funded projects. It has been UCSF's policy to treat hazardous waste disposal as a direct cost, and UCSF's F&A rate does not include any hazardous waste disposal costs. This treatment by UCSF is consistent with OMB Circular A-21 and CAS. It is, however, different from many other universities, including some other UC campuses, which treat hazardous waste disposal as an F&A cost.

2) May federal funds be used to purchase furniture?

Answer: Maybe. Furniture is defined as movable items of convenience such as tables, chairs, desks, etc. used to furnish an office or lab.  It is considered equipment if it is over the $5000 threshold or supplies if it is under the $5000 threshold. Whether or not it is classified as equipment or supplies, furniture may be direct charged to a federal fund only if it is used for a scientific, medical or other technical activity that benefits the project. This applies regardless of whether the furniture will be used at an on- or off-campus location. For example, a table and chair that are needed for interviews with a project's study subjects and specifically designated solely for that purpose could be an allowable direct charge, whereas, a desk or a chair for project staff would not be an allowable direct charge.

3) May departments charge sponsored projects for the cost of an annual retreat?

Answer: Maybe. If the conference is scientific and is allowed under the terms of the award, then it may be direct charged to the federally funded project.  If the conference is of a general nature, then it may not be direct charged to a federally funded project. See UCSF Policy 250-11, Recharges & Common Cost Allocation, Appendix A (Charging for UCSF Sponsored Conferences and Continuing Education Type Courses) for further guidance. 

4) Are lab coats and lab related laundry allowed to be charged on R01 grants?

Answer: Maybe.  Lab coats and lab related laundry charges should be charged to federal grants when the amounts are reasonable and benefit the projects. Often, lab coats and laundry charges benefit more than one project or activity, possibly including Instruction activities. If so, some reasonable allocation of the costs among the projects and activities is needed. It is also important that all projects or activities that benefit from the lab coat or laundry service be treated consistently. So, for example, a privately funded research project benefiting from laundry service should be charged the appropriate share of the laundry service's cost, or that a lab coat benefiting Instruction should be charged to an Instruction DPA.

5) Are employee badges ever allowed to be charged to federal funds?

Answer:  No.  Employee badges are considered part of personnel administration and, so, should not be charged to federal funds.

6) May cost of door nameplates for new employees be charged directly to their funding projects?

Answer:  No.  Employee nameplates are considered part of personnel administration and, so, should not be charged to federal funds.

7) May federal funds be used to pay for health insurance for family members of a post-doctoral fellow working on a federal grant?

Answer:  Yes.  Federal funds may be used to pay for a post-doctoral fellow’s health insurance plan in proportion to the amount of effort on the project.  

8) May the "Institutional Allowance" awarded under the National Research Service Awards (NRSA) be used to pay for the fellow's family health insurance?

Answer:  Yes.  Please see NIH Grants Policy Statement on Training Grants.
9) A fellow in the department needs to take a language class. If he or she is paid on a federal grant, may the cost of the class be charged directly to that grant?

Answer: No. Such classes are not related to the "science" perspective of the project and should be paid by discretionary funds.

10) May training for administrative staff be allowed on a federal grant?

Answer:  No.  Training is not allowed, unless the course directly benefits the science of the federal grant.  This includes campus course offerings, such as RAS, General Ledger, Introduction to Contracts and Grants, etc.

11) I have a few clinical fellows on an NIH T32 grant who see patients and need to carry pagers. Is the cost for their pager service an allowable direct cost?

Answer: Maybe. As long as there are no restrictions on the grant regarding pagers, and seeing patients is part of the scientific aims of the project, the cost is an allowable direct cost. However, if the pager is also used for other clinical or other purposes outside of the T32 grant, it should be charged in a proportionate manner.

12) To attract a large pool of candidates for an Adjunct Assistant Professor position that will act as Principal Investigator of a federally funded award, we advertised the position in three scientific journals. May these advertising costs be direct charged to the award in question?

Answer: Maybe. If you are recruiting for a replacement PI who will be devoting 100% effort to the award, the advertising costs may be directly charged to the project. If the effort of the PI is split between the federally funded project and other activities, e.g. Instruction, Other Sponsored Activities, the advertising costs should be proportionally charged to these activities.

13)  Are entry visa filing fees and premium processing fees allowable costs on federally funded grants?

Answer:  Yes and no, respectively.  Entry visa filing fees for non-student employees working on grant and contract awards are allowable on federal awards.  These should be budgeted in the “other costs” category and charged proportionate to the level an individual is working on an award.  The NCA to use for entry visa filing fees is 437575.

Premium entry visa processing fees for non-student employees that provide an expedited review of an entry visa application by the government are not allowable on federal awards.  The NCA to use for premium entry visa processing fees is 437576.

14)  Can I charge human subject protocol review fees (aka IRB fees) to sponsored awards?

Answer:  Sometimes.  Industry sponsored awards may be charged IRB fees.  Government and non-profit awards may not be charged IRB fees.

Cost Overruns

1) How should cost overruns be handled?

Answer:  Cost overruns occur when actual project costs exceed the sponsor's funding.  Actual project costs should be accumulated in the sponsored project DPA-Fund, even if this creates a deficit situation.  The deficit should be cleared before any reporting to the sponsor by posting a deficit transfer journal with the following:

Miscellaneous Questions

1) My department Chair wants to issue "clearer guidelines" on CAS to department personnel. How should I proceed?

Answer: UCSF wants to maintain as much flexibility as possible while also complying with the CAS requirements (at least when charging federally funded projects). There has been relatively little definitive guidance from the federal government on what are allowable vs. unallowable practices under CAS. All definitive federal guidelines are included in the campus issued Cost Accounting Standards (CAS) guidelines. The campus issued this document, and the related training materials, with the intent of meeting the needs of management and CAS compliance given the best information available. Departments issuing "clearer guidelines" for charging than those already issued campus-wide could potentially result in the following consequences: 1) decreased charging flexibility, 2) raise a consistency issue if other departments do not also issue "clearer guidelines", and 3) raise a consistency issue if one department's "clearer guidelines" conflict with another department's "clearer guidelines" regarding a particular charging practice. We therefore discourage departments from issuing their own "clearer guidelines."
Departments are welcome to submit questions to get additional clarification of these guidelines.  As appropriate, the Guidelines will be updated so that all departments may benefit from the clarifications or additional information. Inquiries and suggestions should be directed to Charles Taylor (ctaylor@finance.ucsf.edu) or Matt Suelzle (msuelzle@finance.ucsf.edu) in Budget and Resource Management.

 

This page last updated on: Tuesday July 22 2008