GAP 200.330, Facilities and Administrative (Indirect) Costs on Sponsored Projects

  1. Applicability
  2. General
  3. Definitions
  4. Charging F&A Costs
  5. Exclusions
  6. F&A Rate for Subrecipients

 


 

I. APPLICABILITY

Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133.  Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200:  Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance).  It is important to verify the appropriate regulations applicable to your award.  Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency.  Note that subawards issued under this GAP follow the same regulatory applicability as the prime award.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-Federal sponsor’s policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc.  Unless otherwise noted, this GAP applies to all sponsored projects, unless superseded by guidelines from Non-Federal sponsors.

 

II. GENERAL

Per OMB Circular A-21 and 2 CFR, Part 200 "The principles are designed to provide that the Federal government bear its fair share of total costs…" The mechanisms to accomplish this are Directs Costs as discussed in GAP 200.320, Direct Costing on Sponsored Projects and Facilities and Administrative (F&A) costs, previously known as indirect costs. The F&A rate charged to a federally-sponsored project is negotiated with the Department of Health and Human Services (DHHS).

 

III. DEFINITIONS

Government Definition of F&A costs:
According to OMB Circular A-21 and the Uniform Guidance (2 CFR, Part 200), F&A costs are "costs that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity."

Examples include:

  • Salaries, wages and fringe benefits for clerical and administrative positions not allowable as direct costs, unless specifically budgeted and approved by the sponsor.  (See GAP 200.360, Administrative and Clerical Expenses)
  • Departments such as procurement services or payroll services
  • Memberships
  • Subscriptions
  • Library books
  • Periodicals
  • General purpose office supplies
  • General purpose equipment
  • Janitorial services
  • Photocopying charges (for general business use)
  • General use postage
  • Repair & maintenance
  • Sanitation services
  • Local telephone service not allocable directly to a sponsored project
  • Utilities, etc.

Government Definition of Direct Costs:
Direct costs are those costs that can be identified specifically with a particular sponsored project, or that can be directly assigned to such activity relatively easily with a high degree of accuracy. GAP 200.320, Direct Costing on Sponsored Projects has specific information and procedures for charging sponsored project for Direct Costs. It is very important that expenses are appropriately charged.

Unallowable Costs:
For either F&A costs or Direct Costs OMB Circular A-21 and 2 CFR, Part 200 identifies specific activities or transactions that are not allowed to be charged to sponsored projects, either as a direct cost or an F&A cost. The following costs have been specifically identified by the Government as unallowable on Government funded sponsored projects.

Unallowable costs, including but not limited to the below, can only be charged with explicit approval from sponsor. Individual agency and program requirements may list other "unallowable" costs; the following list is not all-inclusive:

  1. Advertising for general promotion of the University, including printed materials, promotional items, memorabilia, gifts, and souvenirs
  2. Alcoholic beverages
  3. Alumni or fund-raising activities
  4. Antiques
  5. Bad debt write-offs
  6. Contributions and Donations
  7. Commencement expenses
  8. Cost Overruns; any costs allocable to a particular sponsored agreement may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.
  9. Costs on Industry, Foreign Government or Other Non-Government Grants/Contracts; any costs allocable to activities sponsored by industry, foreign governments or other sponsors may not be shifted to federally-sponsored agreements.
  10. Decorative objects for private offices
  11. Entertainment
  12. Fine/original art
  13. Fines and penalties
  14. Flowers
  15. Goods or services for personal use
  16. Lobbying
  17. Memberships in airline travel clubs
  18. Memberships in civic, social, community organizations or country clubs
  19. Faculty and exempt staff salary in excess of base rates paid by the institution.
  20. Selling or marketing products or services of the University
  21. Social events
  22. Other limitations may apply, such as the Public Health Service salary cap.

In order to ensure that unallowable costs are not included in F&A, it is critical that all expenses are charged to the appropriate G/L account.

 

IV. CHARGING F&A COSTS

All applications for sponsored research, education, and outreach (public service) projects will generally have associated F&A costs. These F&A charges are real expenses incurred in the conduct of projects and need to be recovered from the sponsor. It is expected that the standard F&A rate will be used in all applications. If the rate indicated is a non-standard rate, justification for the rate should be submitted with the Duke Proposal Approval Form and will be evaluated according to stringent guidelines by the Dean’s Office for the Medical Center (via the Office of Research Administration) and the Office of Research Support on behalf of the Provost for the University.

The University's standard rates are found on the F&A/Indirect Cost Rates webpage. The appropriate F&A rate is to be indicated on the Duke Proposal Approval Form, and should be used in the budget calculations.

Based on the agreed upon F&A rate and any specific details that apply to the award, the Office of Sponsored Programs calculates the F&A charge on a monthly basis as part of the month end process. The Post Award Administration Manual details this process.

V. EXCLUSIONS

Per Duke University’s negotiated F&A Rate, the following guidance is applicable:

§200.68 Modified Total Direct Cost (MTDC)

MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and subawards and subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward and subcontract in excess of $25,000.

 

VI. F&A RATE FOR SUBRECIPIENTS

(For awards subject to the Uniform Guidance 2 CFR, Part 200)

a. Under Federal Uniform Guidance, a subrecipient may budget and charge any of the following as an allowable indirect (F&A) cost rate:

  • an approved federally recognized indirect (F&A) cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists,
  • a de minimis indirect (F&A) cost rate (currently 10% of Modified Total Direct Costs) as defined in 2 CFR §200.414 Indirect (F&A) costs, paragraph (f) of Subpart E, or
  • in extreme circumstances:
    • an indirect (F&A) cost rate negotiated between the pass-through entity and the subrecipient (in compliance with 2 CFR Part 200) , or
    • an indirect (F&A) cost rate in compliance with specific sponsor or award terms and conditions

b. Uniform Guidance Section 200.414 advises that subrecipients may elect to charge a de minimus rate of 10% of modified total direct costs (MTDC) which may be used indefinitely.  Please note that certain federal agencies have limited the international rate to 8%; be sure to check agency-specific guidance for additional information. In developing budgets with subrecipients that do not have a federally negotiated F&A rate, Duke University recommends that the de minimis rate be discussed with the subrecipient prior to submission of the proposal, and that this rate should be incorporated into the Duke University budget and budget justification.

c. While strongly discouraged, in cases of exceptional circumstances, the subrecipient may need to qualify for an indirect (F&A) cost rate negotiated directly with Duke.  In this situation the subrecipient, at a minimum, must provide the following information.

  • most recent fiscal year-end financial statements reviewed by an independent public accounting firm and,
  • most recent fiscal year-end trial balance that ties to the financial statements and,
  • indirect (F&A) cost rate proposal, including calculated and requested indirect (F&A) cost rate.

For further detail on F&A rates for subrecipients without a formally negotiated rate, please see UGC 4.0, F&A for Subrecipients Without a Formally Negotiated Rate.

Note: If the Federal program has a published cap on F&A recovery, that rate must be applied regardless of the availability of a de minimus rate.

Projects with funding awarded prior to December 26, 2014 are not subject to this guidance listed in Section IV herein and should follow Duke University internal policy for approval.

 

 

 

Note:This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.