DIRECT CHARGING POLICIES
Direct Charging Policies
Transmittal Memorandum
Introduction
Interim Guidelines
Questions and Answers
Quick Reference Guide
Direct Charges
The following is a replication of the 'Interim Guidelines For Direct-Charging
Costs to Grants' manual issued August 7, 1997. The Guidelines were written to
provide reference and guidance for Principal Investigator and Grant Administrators
for the consistent treatment of charges to sponsored research agreements.
In general, these guidelines apply to federal and non-federal grants and contracts. Exceptions are possible on non-federal grants and contracts, and are specific to sponsor guidelines.
Contact the Office of Sponsored Projects Accounting with any questions or comments.
To: Current holders of guidelines for direct-charging costs to grants
From: Sponsored Projects Accounting
Subject: Guideline revision and restatement
Date: April 13, 1999
Enclosed is Washington University's revised policy statement on direct-charging costs to sponsored research agreements. Please replace your current "Interim Guidelines for Direct-charging Costs to Grants" (the blue binder) pages with these revised pages.
This revision to the "Interim Guidelines for Direct-Charging Costs to Grants" responds to changes made to OMB Circular A-21 on May 8, 1996, including:
Terminology. Circular A-21 replaced the term "indirect cost" with "facilities and administrative (F&A) cost." Within the context of this manual the terms "indirect cost" and "F&A cost" are interchangeable. The title, "Guidelines for Direct-charging Costs to Grants" replaces the original policy statement title, "Interim Guidelines for Direct-charging Costs to Grants."
Direct-charging administrative costs. OMB incorporated four Cost Accounting Standards (CAS) into Circular A-21. These standards defined more stringent requirements for direct-charging such costs as office supplies, postage, memberships and local telephone, fax and data lines. Circular A-21 does not absolutely bar such costs from being charged directly to a grant. The new Circular requires these normally indirect costs be specifically identified with a grant and be incurred under unlike or special circumstances. Refer to page 10.
Consistency. The Cost Accounting Standards also mandate that consistency in treating costs as direct or F&A be maintained on an institution-wide basis. The revised circular requires these rules be consistently applied across the University (i.e., all subdivisions of the University must treat all similar circumstances consistently). The University can no longer allow divergence in the treatment of costs between departments, even when consistent within a department. Refer to page 16
Principal Investigator Financial Management. A new section defines minimum financial management requirements that PIs must observe in managing sponsored agreement funds. Refer to page 17.
Updated Quick Reference and Q & A. The "Quick Reference Guide" provides specific and detailed guidance on appropriate means of establishing and documenting specific identification and unlike circumstances for many common costs. The Q&A section adds new questions and updated answers reflecting the latest A-21 changes.
Contact the Director of the School of Medicine's Office of Gifts, Grants & Contracts (362-6876) or the Manager of the Office of Sponsored Projects Accounting (935-7089) with any questions or comments.