Consistent Treatment of Costs in Like Circumstances

CAS 502 requires that costs incurred for the same purpose, in like circumstances, be treated as either direct or indirect costs of sponsored programs

This means that for any type of cost, including salaries and wages, lab and office supplies, equipment repair and maintenance, and services, all departments must treat that cost in the same manner. Certain types of costs have been designated as indirect costs; they should not be directly charged to federally sponsored programs except in "unlike circumstances" An unlike circumstance is defined as an amount or purpose of use that is significantly greater or different than is routinely the case in academic departments. Compliance with CAS 502 includes identification and -justification of costs in proposal budgets and proper use of expense objects. Administrative and clerical costs require special attention.

Administrative and Clerical Expenses

In accordance with OMB Circular A-21, most federal awards may not charge as direct costs the salaries of administrative and clerical staff or certain office expenses. Exceptions may include large center grants and program projects and projects requiring a level of service significantly greater that what is routinely provided by academic departments. Large center grants and program projects-as well as grants that require extensive database management, individualized graphics or manuscript preparation, human or animal protocol preparations or other project-specific regulatory protocols-may qualify for an exception. To comply with Circular A-21, proposals to the federal government that include clerical and administrative salaries or office expenses should contain justification for such expenses. Unless included in an approved budget or approved by the federal agency in writing, these items cannot be charged as direct costs to federal projects.

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