GAP 200.340, Cost Accounting Standards (CAS) on Sponsored Projects

I.    Purpose

II.   Types of Cost

III.  Cost Accounting Standards (CAS)

IV.  Federal Regulations

I. Purpose

As an institution of higher education in receipt of federal funds, Duke University is required to comply with the Cost Accounting Standards (CAS) referenced in Subpart E of 2 CFR 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the UG).

This General Accounting Procedure describes the institutional expectations and resources for complying with the CAS.

Reportable projects, which are those projects where invoices and financial reports are submitted by an institutional office (Post-Award Financial Management or Treasury & Billing Services) and are represented by the 20x-28x, A03 and 30x-38x WBSE ranges, are subject to CAS.  These include:

• All federal awards
• All awards that contain any federal flow-through funds
• Awards with terms and conditions which reference the UG or CAS
• Sponsored projects whose funds are being used as cost sharing on a CAS covered project, only the individual cost(s) being used as cost sharing will be subject to the definitions of direct costs and “unlike circumstances”
• Awards not covered under CAS are still subject to the requirements listed in the award and University guidelines

The UG also requires the institution to complete the disclosure statement (DS-2), which is a comprehensive description of an organization’s cost accounting practices. This statement includes direct costs, Facilities & Administrative (indirect) costs, depreciation and use allowances, leave costs and applicable credits, and deferred compensation/insurance costs. The DS-2 requirement applies to all institutions receiving sponsored projects totaling $50 million or more that are subject to the CAS. The DS-2 will be reviewed and revised/updated as necessary. Revisions and additions will be submitted in accordance with 2 CFR Part 200, Subpart E.  Please note that contracts subject to CAS standards awarded to the University are also subject to the CAS requirements at 48 CFR 9900 through 9999 and 48 CFR part 30 (FAR Part 30)-(200.419).  Please contact the Office of Post Award Administration for further information.

II. Types of Costs

Facilities & Administrative (F&A) or indirect costs:
Indirect costs are costs incurred for common or joint objectives, which cannot be identified with a specific activity, whether sponsored project, instructional or other institutional purpose. 

Refer to GAP 200.330, Facilities and Administrative (Indirect) Costs on Sponsored Projects for futher information.

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.

Refer to GAP 200.320, Direct Costing on Sponsored Projects, for futher infromation on procedures for charging sponsored research for Direct Costs.

Unallowable Costs:
The Uniform Guidance addresses selected costs in Sections 200.420-200.476, providing principles to determine allowability.  Several specific cost items are identified as unequivocally unallowable on a sponsored project, either as a direct or an indirect cost, including for example alcohol as entertainment, bad debt, personal use of automobiles, and losses that could have been covered by insurance.  Other cost items can only be charged with the prior written approval from the sponsor, including for example entertainment, buildings and land, and student activities.  Individual sponsor and project requirements may identify additional unallowable costs; GMs and PIs must review sponsor policies and award documents for specific guidance.

The list below is not all-inclusive.  Individual agency and program requirements may list other "unallowable" costs.

1. Advertising for general promotion of the University, including printed materials, promotional items, memorabilia, gifts, and souvenirs
2. Advertising for recruitment purposes that includes color or is excessive in size
3. Alcoholic beverages
4. Alumni or fundraising activities
5. Antiques
6. Bad debt write-offs
7. Charitable Contributions
8. Commencement expenses
9. Decorative objects for private offices
10. Entertainment
11. Fine/original art
12. Fines and penalties
13. First-class/business-class air travel differentials
14. Flowers
15. Gifts, prizes and awards
16. Goods or services for personal use
17. Lobbying
18. Memberships in airline travel clubs
19. Memberships in civic, social, community organizations or country clubs
20. Faculty and exempt staff salary in excess of base rates paid by the institution
21. Selling or marketing products or services of the University
22. Social events

III. Cost Accounting Standard (CAS)

IV. Federal Regulations

This GAP reflects the provisions of the UG, which effective as of December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

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.

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.