Understanding the Fundamental Cost Principles is essential to managing your award successfully. Federal regulation can be found at Guiding Principles – OMB Uniform Guidance Subpart E – Cost Principles.
Here are the basics:
Total Project Costs = allowable direct costs (DC) + allowable indirect costs (IDC, or facilities and administrative costs F&A)
Costs must be:
- Allowable
- Allocable
- Reasonable
- Consistently treated
What is Allowable?
- Must be reasonable;
- Allocable to sponsored agreements
- Consistently treated
- Conform to sponsored agreement
- Sponsored agreement takes precedent over cost principles
What is Allocable?
- Item can be assigned (allocated) to an activity or function
- In proportion to the benefit received
- Direct costs: exclusive benefit to project or can be assigned to multiple projects in proportions that can be approximated through reasonable methods.
- Indirect costs: benefit many projects or activities, can’t be reasonably assigned.
- In proportion to the benefit received
What is Reasonable?
- When you bought the item at price X and quantity Y
- You acted prudently; others would have made similar decision given facts and circumstances at the time the decision was made, i.e.:
- necessary
- followed good business practices and applicable laws and regulations, and sponsored agreement terms and conditions
- acted prudently given the circumstances
- followed institutional policies
- You acted prudently; others would have made similar decision given facts and circumstances at the time the decision was made, i.e.:
What is Consistently Treated?
- Like costs, must be treated the same for similar purposes
- If in F&A pool, there it stays, UNLESS cost is not for same kind of purpose
- If allocated to one activity/project, can’t shift to another activity
- If charged to one award, can’t shift to another because there’s money in the other pot. (Spending down the award is not allowable!)
What is Allowable as a Direct Cost:
- Needed to support project
- Cost to sponsor in proportion to benefit received
- They pay the whole cost, they are the sole beneficiary
What is Allowable in F&A (not Direct Cost)
- Needed to support many projects.
- Not reasonable to assign proportion of benefit, including but not limited to
- Secretary/clerical (cost of doing business)
- Office supplies (cost of doing business)
- Local phone calls (cost of doing business)
What about Food?
- Food is considered entertainment (OMB Uniform Guidance Part 200.438) and is not allowable
- Unless for a conference/meeting (OMB Uniform Guidance Part 200.432)
- Purpose: disseminate sponsor’s results (Remember: How does expenditure allow you to achieve the project’s objectives?)
- Characteristics of meeting: formally announced, agenda, list of attendees, minutes, proceedings, etc.
- This documentation should be available for inspection to justify expenditure
- If not in budget justification, sponsor approval should be obtained
Core Questions to consider when using award funds:
- How does purchase/expenditure (as DC) help accomplish the project’s objectives?
- If cost is administrative (i.e., generally in IDC/F&A), how is the need in this specific situation non-routine, unlike?
- Is item not-allowed in agreement?
- Is prior approval necessary? (e.g. international travel)
- If prior approval needed and not obtained, cost will not be allowed
- Is it a reasonable purchase?
- DOCUMENTATION: How purchase advances project’s objectives (i.e. allowable, reasonable, necessary, allocable, consistently treated)
- If not in budget justification,
- Then justification should ordinarily be included in purchase requisition