With reference to my vague summary of "Another NMR Cost Survey" several of
you have asked what are Fed Guidelines? The web site link for OMB
Circular a-21 (and I'm sure there are others) I bow to is:
http://www.whitehouse.gov/omb/circulars/a021/fedrega21.html
http://www.whitehouse.gov/omb/circulars/a021/a021.html
which is for: A. Purpose of Circular A-21. Office of Management and Budget
(OMB) Circular A-21, "Cost Principles for Educational Institutions," establishes
principles for determining costs applicable to Federal grants, contracts, and
other sponsored agreements with educational institutions. "
Adjustment of previously negotiated F&A cost rates containing unallowable costs.
Negotiated F&A cost rates based on a proposal later found to have included costs that (a) are
unallowable as specified by (i) law or regulation, (ii) Section J of this Circular, (iii) terms and
conditions of sponsored agreements, or (b) are unallowable because they are clearly not allocable to
sponsored agreements, shall be adjusted, or a refund shall be made, in accordance with the
requirements of this section. These adjustments or refunds are designed to correct the proposals used
to establish the rates and do not constitute a reopening of the rate negotiation. The adjustments or
refunds will be made regardless of the type of rate negotiated (predetermined, final, fixed, or
provisional).
a. For rates covering a future fiscal year of the institution, the unallowable costs will be removed
from the F&A cost pools and the rates appropriately adjusted.
b. For rates covering a past period, the Federal share of the unallowable costs will be
computed for each year involved and a cash refund (including interest chargeable in accordance with
applicable regulations) will be made to the Federal Government. If cash refunds are made for past
periods covered by provisional or fixed rates, appropriate adjustments will be made when the rates
are finalized to avoid duplicate recovery of the unallowable costs by the Federal Government.
c. For rates covering the current period, either a rate adjustment or a refund, as described in
subsections a and b, shall be required by the cognizant agency. The choice of method shall be at the
discretion of the cognizant agency, based on its judgment as to which method would be most practical.
d. The amount or proportion of unallowable costs included in each year's rate will be assumed
to be the same as the amount or proportion of unallowable costs included in the base year proposal
used to establish the rate.
12. Accounting for unallowable costs.
a. Costs expressly unallowable or mutually agreed to be unallowable, including costs mutually
agreed to be unallowable directly associated costs, shall be identified and excluded from any billing,
claim, application, or proposal applicable to a sponsored agreement.
Section J:
9. Contingency provisions. Contributions to a contingency reserve or any similar provision made for
time, intensity, or with an assurance of their happening, are unallowable. (See also Section J.21.c.)
12. Depreciation and use allowances. Institutions may be compensated for the use of their buildings,
capital improvements, and equipment, provided that they are used, needed in the institutions' activities,
and properly allocable to sponsored agreements. Such compensation shall be made by computing
either depreciation or use allowance.
Jim Loo
NMR Facilities Manager
UCSC
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As Zeus said to Narcissus, "Watch Yourself."
loo_at_chemistry.ucsc.edu
http://www.nmr.ucsc.edu
(831) 459-2485 Office
(831) 459-4923 Lab
(831) 459-2935 FAX
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Received on Thu Mar 29 2001 - 17:42:45 MST