The federal government is the largest sponsor of research and other scholarly activities at Saint Joseph’s University. For that reason, the cost policies of the federal government, contained in OMB Circular A-21, set the standard for all sponsored activities.
For a cost to be allowable and chargeable to a sponsored program, it must meet the following tests:
- Reasonable (Would a prudent person incur this expense?)
- Allocable (Is the expense beneficial to the project?)
- Consistent with University costing practices (Is the expense treated the same way regardless of source funds?)
If the sponsored agreement specifically states the expense is unallowable, it cannot be charged to the project irrespective of its appropriateness to the project.
The table below gives information regarding the allowability of some of the most common items of costs charged as direct. In the case of inconsistency between the provisions of a specific agreement and the provisions below, the provisions of the specific agreement should govern. It is also recognized that Saint Joseph’s University enters into agreements with private sponsors who have specific rules regarding costing policies. If those agreements are not for research projects but are for other activities, certain exceptions to the following guidelines may be made.
Salaries, Wages and Benefits
- Graduate Assistants
- Student Employees
- Technical Personnel
- Administrative and clerical staff
Costs of personnel are allowable on research agreements to the extent supported by actual effort performed on the project and approved in the award budget. Periodic effort certifications will be used to document the actual effort performed. An individual’s base salary must be used to compute the cost charged to a sponsored agreement; extra compensation or supplemental pay for work on sponsored agreements. The following exceptions apply:
Direct charging of administrative and clerical salaries may be appropriate where the nature of the work performed under a particular project requires an extensive amount of administrative or clerical support that is significantly greater that the routine level of such services provided by academic departments. The charging of these costs directly would need to meet the following general criteria:
- The cost must be relatively easily and specifically identified, with a high degree of accuracy, with a particular sponsored project.
- The special circumstances requiring direct charging of these services must be justified to the satisfaction of the awarding agency.
- It is a general rule that when the size, nature, and complexity of the project justifies administrative or clerical costs, the amount of effort put forward by the administrative or clerical staff member to the project should be at least 20%
Some examples of circumstances where direct charging salaries of administrative or clerical personnel may be appropriate are as follows:
- Large, complex programs, such as those involving large research centers, program projects, and other agreements that entail assembling and managing teams of investigators from a number of institutions.
- Projects that involve extensive data accumulation, analysis, and entry; surveying; tabulation; cataloging; searching literature; and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies).
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects where the principal focus is the preparation and production of manuals and large reports, books, and monographs (excluding routine reporting requirements).
- Projects that are geographically inaccessible to normal departmental administrative services, such as field sites that are remote from the campus.
- Individual projects requiring significant amounts of project specific database management; individual graphics or manuscript preparation; human or animal protocols, IRB preparations, and/or other project-specific regulatory protocols; and multiple project-related investigator coordination and communications
These examples are not exhaustive nor are the intended to imply that the charging of administrative or clerical salaries would always be appropriate for the situations illustrate in the examples above. Where direct charges for administrative and clerical salaries are made, care must be exercised to assure that costs incurred for the same purpose in like circumstances are consistently treated as direct costs for all activities.
Business Meals and Meeting Costs
- Only when specifically permitted by the sponsor award or agreement.
Donations and Contributions
- Unallowable unless specifically approved.
- Scientific: Allowable when the equipment is necessary and will be used primarily, or exclusively, for the project(s) to which the costs will be charged.
- General Purpose: (e.g., desks, file cabinets, fax machines, computers): Unallowable unless specifically approved in the sponsored agreement or subsequently approved by the sponsor. In the case of computers, if a computer is essential to the performance of the work and will be used solely for such a project, costs may be allowable without further agency approval.
- Costs of Internet connections from a person’s home are generally unallowable.
- Local telephone costs are generally unallowable as a direct cost. However, there are certain circumstances where these charges may be directly charged to a research project.
Long Distance Telephone
- Allowable when specifically identified with an individual project.
Materials (supplies, purchased materials, etc.)
- Project Supplies: Items such as chemicals, laboratory supplies, and even pens, pencils, folders, notebooks, and the like that can be identified as being “exclusively for the support of” a sponsored agreement are allowable.
- Office Supplies: Items commonly found in any office such as wall clocks, calendars, waste cans, letterhead, staples, etc. that would likely be used for purposes other that the award are unallowable except in specific circumstances.
- Routine Postage Costs: Unallowable except where a project requires specifically identifiable large mailings or the like.
- Special Mailings or Delivery Costs: Allowable when necessary for the success or completion of a project (example: overnight delivery charges for shipment of research materials to collaborators or from suppliers).
- Unallowable unless approved under the provisions of the specific funding agency.
- Consultant fees are an allowable charge to sponsored agreements. Sponsor guidelines should be checked. “Honorariums” are typically not allowed; rather payments to consultants are for services received.
Publications (books, subscriptions)
- Unallowable unless approved by the funding agency or essential to the daily conduct of the project and not readily available from other sources (such as the library).
Scholarships and Student Aid
- Unallowable to research projects.
- Allowable if specifically benefiting the project.