Tam Tran
Assistant Director, Sponsored Projects
Diane Nunes
Compliance Officer, Contracts and Grants Accounting
November 13, 2013

 Cost Principles A-21 (section C: Basic
Considerations)
– Reasonable
– Allocable
– Allowable
– Consistently Treated
– http://www.whitehouse.gov/omb/circulars_default
Quality Research Administration Meeting

Reasonable: Public opinion test- any prudent person would purchase this item and pay this price
Allocable: There is a direct relationship between each item purchased and the project
Allowable : The cost must follow the Sponsored Agreement terms and federal policies
Consistently Treated: At the institutional level, costs, direct and indirect, must be treated the same in like circumstance.
• Must meet all four standards to remained charged to the Award
Quality Research Administration Meeting

CAS Required by OMB A-21 (revised May 1996)
• CAS 501: requires educational institutions to use consistent cost accounting practices for estimating, accumulating and reporting costs for sponsored agreements
• CAS 502: requires education institutions to treat all costs incurred for the same purpose, in like circumstances, consistently as either a direct cost or facilities and administrative (F&A)costs
• CAS 505: requires the exclusion of all costs that are expressly unallowable or mutually agreed as unallowable from any proposal, application, claim or billing
• CAS 506: requires the consistent use of the same cost accounting period (ie, the University’s fiscal year)
Quality Research Administration Meeting

• Public Law 100-679- Require CAS Disclosure
Statement (DS-2)
• Identify accounting practices, policies, and procedures for assigning costs to federally sponsored programs and attest to consistent treatment of those practices
• http://snap.uci.edu/viewXmlFile.jsp?resourceID=5186
Quality Research Administration Meeting

Question: Can alcohol be charged to project?
• Award Terms and Conditions (first place to determine whether cost can be charged to project)
• Program Rules
• Agency Terms and Conditions
• OMB Circular A-21
• Keep in mind of Public Law and Institutional Policy
Quality Research Administration Meeting

• Moving expenses (relocation costs)
• General use software
• Air conditioner
• Visa fees (foreign researcher)
• Lab key
• Air fare
Quality Research Administration Meeting

• Does the expense meet award terms and conditions?
• Does it meet specific program rules?
• Does it meet agency terms and conditions?
• Does the expense meet OMB A-21 criteria?
• Does the PI justification connect the cost to the work of the project that will be charged?
Quality Research Administration Meeting

• Its not the nature of a good or service that’s in question, but how it directly benefits a project.
• It is appropriate to ask/verify how an item is allocable to a project.
• To avoid audit disallowance –DOCUMENT!
• Secure prior approval for rebudgeting through
Sponsored Projects
Quality Research Administration Meeting

• We are required and empowered to advise the PI and protect the University from the ramifications of inappropriate charges.
• Sponsored Projects and C&G Accounting are available when you need clarification/assistance.
• Non-compliance can expose University to financial risks
• Non-compliance can jeopardize UCI’s ability to accept future federal funding
Quality Research Administration Meeting

Quality Research Administration Meeting