1. When an institution receives federal awards, what government regulations apply?

For all Federal awards (grants and contracts)

  • Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions
  • The terms and conditions contained in the award

For Federal grants

  • OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations

For Federal Contracts

  • Federal Acquisition Regulations (FAR) and the agency supplement to the FAR for the agency awarding the contract. The FAR regulations are available at http://www.arnet.gov/far/


The OMB Circulars are available at the Office of Management and Budget website (http://www.whitehouse.gov/OMB/) or through links at the Office of Contract and Grant Accounting (OCGA) website (http://www.vanderbilt.edu/ocga/useful/useful.htm).

For questions relating to the interpretation of government regulations contact DSR, 322-2631 or OCGA, 343-6658.

 

2. How much flexibility do I have in reallocating funds between budget lines on my grants?

Guidance for reallocating funds between budget lines on Department of Education, National Institutes of Health (NIH)/Public Health Service (PHS) and National Science Foundation (NSF) grants is available on the Division of Sponsored Research (DSR) website (http://www.vanderbilt.edu/SponsoredResearch/PostAwardAgency.htm).

Guidance for reallocating funds on grants from other agencies and for Federal contracts is available by referring to your award or by contacting DSR at 322-2631.

 

3. Where can I learn more about Vanderbilt's policy for direct charging of costs to sponsored programs?

Vanderbilt's policy for direct charging of costs is available at http://www.vanderbilt.edu/ocga/vupolicies/directcost/directcost.htm

Copies of the policy can be obtained by contacting OCGA. For interpretations of the policy contact OCGA or DSR.

 

4. Does Vanderbilt's policy for direct charging of costs apply to non-federal projects?

No. The direct charge policy only applies to Federal awards.

 

5. What are some examples of typical direct and indirect costs at Vanderbilt?

Examples of Costs that are NOT Normally Considered as Direct Costs at Vanderbilt University

At Vanderbilt University, the following costs are NOT normally budgeted and charged as direct costs of sponsored projects:

  • Salaries of individuals engaged in routine departmental or administrative work that benefits all activities of the department (instruction, research, training, public service, etc.), i.e., there is no direct relationship to a specific sponsored project's scope of work
  • Supplies and materials for routine departmental or administrative activities of the department that benefit all activities of the department (instruction, research, training, public service, etc.), i.e., there is no direct relationship to a specific sponsored project's scope of work
  • Other costs such as travel, repairs, fees and services, local and long distance telephone expenses, copying and postage that are for routine departmental or administrative use, and do not have a direct relationship to a specific sponsored project's scope of work

Examples of Costs that ARE Normally Considered as Direct Costs at Vanderbilt University

At Vanderbilt University, the following costs ARE normally budgeted and charged as direct costs. The common element is that the cost is necessary to perform the project's stated scope of work.

  • Salaries and fringe benefits of faculty, technicians, post docs, graduate research assistants and other staff engaged in performing sponsored project's scope of work
  • Supplies and materials necessary for performing sponsored project's scope of work
  • Other costs such as travel, subcontracts, repairs, maintenance, fees and services, telephone expenses, copying, postage, etc., necessary for performing sponsored project's scope of work
  • Capital equipment that is approved by the sponsor (or internally approved if allowed by the sponsor)
  • Service/maintenance agreements on capital equipment approved by the sponsor (or internally approved if allowed by the sponsor)

Identification with the sponsored work (i.e., the scope of work) rather than the nature of the goods or services is the determining factor in determining direct costs. [Office of Management and Budget Circular A-21, Section D.]

EXAMPLES

Clerical Salaries

Clerical salaries CAN be budgeted and charged as direct costs under certain circumstances. Simply knowing the "nature of the good or service", e.g., clerical salary is not sufficient to determine whether the cost is an appropriate direct charge to a sponsored project. In order to make the determination, one must know the cost's relationship to the sponsored work. For example:

  • Clerical salaries that are paid to individuals entering data from a survey that is part of the sponsored project's scope of work may be appropriately charged as direct costs.
  • Clerical salaries that are paid to individuals for routine administrative work such as processing purchase requisitions, reviewing monthly ledgers, processing new proposals, etc., and that benefit all aspects of a department, including research, are normally NOT appropriate direct cost charges. [NOTE: An exception may exist for program/project or "center" sponsored agreements where routine administrative work has been
    described in the scope of work and approved/funded by the sponsoring agency.]

Other Examples

Following are other examples of costs and the circumstances under which they may be incurred. For each cost/circumstance, it is indicated whether the cost would be budgeted and charged as a direct cost under Vanderbilt direct charge guidelines.

 
Direct Costs?
YES
NO
Salaries expense incurred under the following circumstances
1
Processing purchase orders on a research grant (such as an "RO1")
2
Processing purchase orders on a center/program project grant (admin effort documented in proposal as part of scope of work)
3
Proposal development (writing, editing, copying and mailing proposals)
4
Principal investigator effort to write annual project report (may include next budget year's proposal)
5
Data entry (data collected under project scope of work)
6

Data entry - financial transactions for research grant are entered into financial shadow system

(Note: may be considered a direct cost if part of the administrative budget on a program/project or center grant AND approved by the sponsor.

Identification with the sponsored work (i.e., the scope of work) rather than the nature of the goods or services is the determining factor in determining direct costs. [Office of Management and Budget Circular A-21, Section D.]

6. Are direct and indirect cost definitions the same for all institutions?

No. OMB Circular A-21 F.6.b. and Exhibit C of that circular provide general guidance on direct and indirect cost charging however direct and indirect cost charging practices vary between institutions.

 

7. Can I charge an item as a direct cost if the sponsoring agency allows it, even if Vanderbilt normally considers that item as an indirect?

No. Awarding agencies are not in a position to make this determination. In fact, NIH has included language in some of their awards indicating this.

In the early days before the implementation of the Cost Accounting Standards many institutions adopted the position that if a direct cost normally treated as an indirect cost was budgeted and not cut from the budget during the award process then the cost was an allowable exception to the institutions charging practice. In more recent times, awarding agencies have clarified their position in stating that they are not in a position to determine an institution's charging practices. The Cost Accounting Standards requires consistent treatment of costs and shifts the burden of proof to the universities.

 

8. Are proposal preparation costs considered a direct or an indirect cost?

Proposal costs for new projects are considered an indirect cost and the associated costs are treated as departmental administration costs in Vanderbilt's indirect cost rates. Since many non-competing continuation proposals consist of progress reports costs associated with these proposals are to be considered as direct costs.

 

9. Are lab notebooks considered a scientific supply or general office supplies?

If the lab notebook is used in the laboratory for recording notes for a research project then the cost of the notebook can be considered a direct cost and the item recorded as a research supply. If the notebook is used for general purposes not connected to a research project than the cost of the notebook should be considered as an indirect cost and the item recorded as an office supply.

 

10. If I ship research materials to a colleague for use on my research project, can this shipping charge be considered as a direct cost to my research project?

Yes, if the colleague is working on behalf of the research project and it benefits the research project then these shipping charges can be charged as a direct cost to the research project.

 

11. What are the components of Vanderbilt's current indirect cost rate for 2003/2004 and how does Vanderbilt's research rate of 51.0% break down?

FACILITIES
25.0%
Building Depreciation
5.0%
Equipment Depreciation
3.5%
Interest
1.7%
Operations & Maintenance
12.8%
Library
2.0%
ADMINISTRATIVE COMPONENTS
26.0%
General and Administrative
Departmental Administration
Sponsored Projects Administration
Student Services

Mailing/Billing Address
(For USPS or Campus Mail Address)

Office of Contract and Grant Accounting
Vanderbilt University
PMB 401591
2301 Vanderbilt Place
Nashville, Tn 37240-1591

Physical Location
(For Courier Usage Only)

1400 18th Avenue South
Nashville, TN 37212

Office hours: 8 a.m. to 5 p.m., Monday through Friday
Telephone (615) 343-6655; Fax (615) 343-6680

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Updted Last
7/8/11