Table Of Contents

Medical University of South Carolina

Direct and Facilities and Administrative Costing Policies and Procedures
Revised 6/11/99

Table of Contents

Contents. These direct costing policies should be used by Medical University of South Carolina's faculty and staff as the basis for complying with the provisions of the Federal Cost Accounting Standards and the Office of Management and Budget (OMB) Circular A-21. These policies and procedures are organized into the following sections:
 

Procedure Number Description
1.0 Introduction
1.1 Policy Statement
1.2 Effective Date and Implementation Time
1.3 Consistency Requirements 
2.0 General Definitions of Allowable Direct Costs 
2.1 Additional Criteria for Determining Direct Costs
2.2 Direct Costs
2.3 Documentation Guidelines for Direct Costs 
2.4 Unacceptable Direct Costing Practices 
3.0 Facilities and Administrative (Indirect) Costs 
3.1 Charging Normally treated F&A Costs Directly 
3.2 Special Circumstances When Charging Normally Treated F& A Costs Direct May be Appropriate
4.0 Grant Budgets, Rebudgeting and Cost Transfers 
4.1 Budgets
4.2 Rebudgeting
4.3 Cost Transfers
5.0 Direct Cost Allocation Guidelines
5.1 General Statement
5.2 Allocation Guidelines
6.0 Proportional Benefit Rule
7.0 Interrelatedness Rule 
  Exhibit A: Direct and Facilities & Administrative Cost Reference Table
  Direct & Indirect Working Group 

1.0 Introduction

The operation of any enterprise involves costs that pertain to a specific project, as well as general costs. This policy:
        (i) governs all direct and F&A (indirect) cost charged to Federal and non-federal grants and contracts; and
        (ii) has been prepared to ensure that the Medical University maintains adequate control over the charging of costs to grants and contracts awarded to the University. For administrative and accounting purposes these costs are grouped into two categories -- direct and Facilities and Administrative (indirect). Many costs, however, are not discretely direct or Facilities and Administrative (indirect) and may appear in either category, depending on the circumstances. Such is the case in charging costs to federally sponsored projects at colleges and universities. The basic regulations for determining costs charged to federally sponsored projects at educational institutions are set forth in Office of Management and Budget (OMB) Circular A-21: Cost Principles for Educational Institutions.   The Circular established principles for determining costs applicable to sponsored agreements, contracts, and other agreements with educational institutions.

Effective May 8, 1996, Circular A-21 was revised to incorporate four Cost Accounting Standards applicable to educational institutions. These were issued by the Cost Accounting Standards Board (CASB) on November 8, 1994, and the A-21 revision extended the standards to all sponsored agreements. Also, the revision required certain large institutions to disclose their cost accounting practices by the submission of a disclosure statement (DS-2) prescribed by CASB. The MUSC DS-2 was sent to the Department of Health and Human Services on April 30, 1999.

The policy has incorporated the Federal costing principles, Cost Accounting Standards, and generally accepted costing principles of non-federal sponsors. Circular A-21 citations, the parenthetical notation at the end of each reference to A-21 indicates the location of the reference in Circular A-21. 

1.1 Policy Statement

STATEMENT OF GENERAL PRINCIPLES

MUSC believes that the following principles should guide its compliance with the requirements of OMB Circular A-21 and the Cost Accounting Standards.

1.2 EFFECTIVE DATE AND IMPLEMENTATION TIME-FRAME

All proposals submitted to the Office of Research and Sponsored Programs (ORSP) after 7/1/98 must comply fully with these guidelines. Proposals submitted before 7/1/98 could either have been awarded or are pending award as of 7/1/98:

1) In the case where the award has already been made, the costs must be incurred as proposed by the investigator and as awarded by the sponsor. In particular, if costs were proposed direct which are now defined as F&A under these guidelines, the costs could continue to be incurred for the remaining project period with the explicit understanding by the PI that the costs are necessary for the conduct of that project. On these awards, where costs normally treated as F&A were proposed and budgeted by the sponsor as direct costs, the PI will be required to have a line item budget established in the accounting system thru Grants and Contracts Accounting, for the remaining project period based on the originally proposed and awarded budget.

2) In the case where the award has not been made, the costs to be awarded must comply with these guidelines. If costs were proposed inconsistently with theses guidelines, the budget needs to be revised to reflect them. This may or may not require notifying the sponsor, depending upon how the award was negotiated; this will be determined on a case-by-case basis. In general, across the board budget cuts by the sponsor would be an indication that the sponsor does not need to be notified if the costs cut include those that were inconsistently proposed.

1.3. Consistency Requirements

The revised OMB Circular A-21 and the implementation of CAS 502, mandates consistency in making the decision to treat a particular type of cost as direct or Facilities and Administrative (indirect): "Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or Facilities and Administrative (indirect) costs. Where an institution treats a particular type of cost as a direct cost of sponsored agreements, all costs incurred for the same purpose in like circumstances shall be treated as direct costs of all activities of the institution." (A-21Section D.1.)

This requirement has two purposes. One is to help insure that costs are assigned correctly by requiring that they be assigned consistently. A second purpose is to avoid inappropriate charges to the federal government for grants when the grants are charged directly for specified costs - then charged again, through the Medical University's Facilities and Administrative (indirect) cost rate, for the same type of costs incurred for the same purpose and in similar circumstances elsewhere in the Medical University.

While mandating consistency, A-21 does not define explicitly the "purposes" and "circumstances" in which a given type of expense should be treated as a direct or facilities and administrative (indirect) costs. Thus, the definition of these terms may vary by type of cost, and by discipline, within an institution. Moreover, the preceding sections of these interim guidelines themselves provide institution-wide consistency insofar as they provide an institution-wide framework of principles and criteria for the charging of costs directly to grants.

These guidelines assume:

    that each department will assure that consistency is maintained within the department (for the same type of cost incurred for the same purpose in like circumstances);

    that the University's administration will encourage departments with similar funding sources and activities to achieve consistency in their charging practices.

These guidelines do not attempt to identify, at this time, groups of departments with "similar activities." It is assumed that such identification will evolve as the other provisions of these interim guidelines take effect throughout the Medical University.

For every department, these guidelines provide a framework within which the department should establish a set of costing practices and documentation that are consistently applied. There application should be to all organized research, whether sponsored by an outside agency or industry, or funded by the Medical University.

Each department in which research activity occurs must maintain a written and current description of the basis on which it charges all categories of costs directly to grants. This description must reflect actual practice. These descriptions are necessary to support the certifications required as part of the Medical University's indirect cost proposal. We anticipate that in the near future these descriptions will have to be on file with the Medical University administration, for internal and external audit reviews.

2.0 General Definitions of Allowable Direct Costs to Grants

OMB Circular A-21 defines a direct cost as: "Direct costs are those costs that can be identified specifically with a particular sponsored project...or that can be directly assigned to such activities relatively easily with a high degree of accuracy." (A-21 Section D.1) This statement implicitly makes the point that charges to a grant should support the grant's purpose and activity. Such charges cannot be assigned arbitrarily, or for the purpose of simplified budget management that is unrelated to the grant's purpose (refer to Medical University's guidelines, "A Guide for Determining Allowable Costs to Sponsored Agreements").

The following criteria must be considered in determining the allowability of a cost charged to sponsored grants and contracts:

    1) Cost must be reasonable. A cost is considered reasonable if the nature of the goods or services acquired and the amount involved reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision was made to incur the cost.

    2) Costs must be allocable to sponsored agreements under the principles and methods of Circular A-21. A cost is allocable to a particular sponsored project if the goods or services involved are chargeable or assignable to the project in accordance with the relative benefits received.

    3) CAS and the revised Circular A-21 emphasize the importance of consistent application of cost accounting principles. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or Facilities and Administrative (indirect) costs. Where the Medical University treats a particular type of cost as direct cost on a sponsored agreement, all costs incurred for the same purpose in like circumstances must be treated as direct cost for all activities of the institution. Consistent treatment of costs is necessary to avoid inappropriate charges to the Federal government or other sponsors when sponsored agreements are charged directly for specified costs, then charged again, through the Medical University's indirect cost rate.

Principal Investigators, and in some specific instances central administration officials, should review costs to ensure that they are allowable and allocable to a project. Size, nature and complexity of sponsored agreements, although not the final determining factor, are in the aggregate important considerations in determining unlike circumstances. Due to the unique requirements of each sponsored agreement, unlike circumstances are determined on a case by case basis.

2.1 Additional Criteria for Determining Direct Costs

    1) The cost must be included in the awarded budget, or the cost must be permitted within rebudgeting authority granted by the sponsor (refer to rebudgeting policy). When preparing proposals for sponsored projects, the P.I. usually submits a detailed budget. This budget includes line items such as salaries and wages, fringe benefits, travel, supplies and other direct costs. The award reflects the approved budgeted items and becomes a part of the agreement between the Medical University and the sponsor. Only those costs that are included in the budget or rebudgeted costs allowed by the sponsor should be charged. If the cost requires institutional and/or sponsor prior approval after the award is made, the approval must be secured before the cost is incurred.

    2) The cost must not be restricted by the sponsor. Costs that are restricted or unallowable as indicated in the award notice or sponsor guidelines may not be charged to a sponsored project.

2.2. Direct Costs

The following costs are examples of acceptable direct costs, as long as they meet the A-21 requirements cited above and are "identifiable to a particular cost objective [sponsored agreement]," A-21 Section F.6.b.. If a cost cannot be so identified, it cannot be directly charged. The "particular cost objective" requirement means that costs cannot be directly charged if they are incurred for the benefit of research in general, or in the interests of the researcher in general. Purchases for a specific sponsored agreement must identify the grant account number on the invoice, requisition, purchase order, or other payment documents such as IITs.

    1) A researcher's or a technician's salary and fringe benefits are allowable direct costs, when the salary charged is supported by their certified monthly or quarterly effort reports.

    2) Laboratory supplies, related technical costs, long-distance telephone charges, shipping costs (not ordinary postage), photocopy costs, animal care costs, computer costs, travel costs, technical and scientific equipment (and related maintenance agreements), and specialized shop costs should be treated as direct costs (see documentation guidelines below).

    3) Supplies drawn from a central storeroom or inventory may be charged directly to a sponsored agreement if their applicability to the sponsored agreement is recorded at the time of withdrawal. All such costs must be charged to sponsored agreements based on anticipated usage at the time of withdrawal.

    4) Normally, administrative and clerical costs cannot be charged directly to grants. Limited and specified exceptions are described in Sections 3.1 and 3.2.

2.3 Documentation Guidelines For Direct Costs

1) The cost must be identified with an activity in the sponsored project to which the cost is charged:

      a) Long-distance telephone and fax costs should be linked to the sponsored agreement by means of a manual log or grant-specific access code.

      b) Purchases for a specific grant must identify the grant's fund number on the requisition, purchase order, invoice   statement, etc.

      c) Supplies drawn from a common stock or inventory may be charged directly to a grant if their applicability to the grant is recorded at the time or withdrawal, by means of a manual log, for example. All such costs must be charged to grants based on anticipated usage at the time of withdrawal.

2) Documentation of linkage of cost to activity should be done by someone who is in a position to know this linkage; for example,  the person who is making the telephone call; the person who is taking supplies from a common stock; etc.

3) Documentation records must be maintained for a period of three years following the submission date of the project's final financial status report. Documentation in the Medical University's Financial Accounting System is acceptable when complete.

4) Only actual costs may be charged to the grant.

5) Under the guidelines set forth in Section 2.2 of these policies and procedures, direct costs may be distributed across two or more grants.

2.4 Unacceptable Direct Costing Practices

The following direct costing practices are unacceptable because they do not meet the OMB Circular A-21 guideline for a "high degree of accuracy" for the assignment of costs to sponsored agreements:

    1) rotation of charges among grants month by month without establishing that the rotation schedule credibly reflects the relative benefit to each grant;

    2) assigning charges to the grant with the largest remaining balance;

    3) charging the budgeted amount (in contrast to charging an amount based on actual usage);

    4) assigning charges to a grant in advance of the time the cost is incurred;

    5) identifying a cost as something other than what it actually is, for example, instructional costs charged as research costs;

    6) charging expenses exclusively to sponsored agreements when the expense has supported other activities;

    7) assigning charges that are part of the normal administrative support for grants, for example, proposal preparation, accounting, payroll; see Sections 3.1 and 3.2 for more details.

3.0 Facilities and Administrative (Indirect) Costs

Facilities and Administrative (F&A) costs are defined in OMB Circular A-21 as "those 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" (A-21 Section E). Facilities costs include: depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements, operations and maintenance and library expenses. "Administration" is defined as: general administration and general expenses, departmental administration, sponsored programs administration, student services, and all other types of expenditures not listed specifically under one of the subcategories of Facilities, (A-21 Section F).

At the department level "salaries of administrative and clerical staff...items such as office supplies, postage, local telephone costs, and Medical University memberships shall normally be treated as F&A costs." (A-21 Section, F.6.b.) Costs incurred for the same purpose in like circumstances must be consistently treated by the University as either direct or F&A.

The Exhibit A lists a variety of costs and identifies their treatment by the Medical University as either direct or F&A.

3.1 Charging Normally Treated F&A Costs to Sponsored Projects

OMB Circular A-21 does not absolutely prohibit costs identified by the Medical University as F&A from being charged directly to a sponsored agreement. However, strict criteria must be met to process transactions to meet the allowability of A-21 and the Cost Accounting Standards.

Costs normally treated by the Medical University as F&A may be charged to a sponsored project when all of the following conditions are met:

1) The costs are incurred to meet the special purpose or requirements of the sponsored agreement defined in the section below, and

2) The cost can be readily identified specifically with the project with a high degree of accuracy; and

3) The cost is explicitly budgeted, with justification, and approved by ORSP and the sponsor as follows:

    a) The cost is separately budgeted in the proposal budget (note that for certain fixed-price funding arrangements a detailed budget is not required by the sponsor; however, the internal budget should reflect the cost.),

    b) The budget amount reflects a realistic estimate of the cost and, in the case of salary, the percent of effort,

    c) Justification is given for the cost. In the case of federal sponsors, the "Budget Justification" section of the proposal should state that the costs are normally treated as F&A by the Medical University, but are being proposed as direct due to the project's special purpose or circumstance as described in the technical proposal and outlined in the "Budget Justification".

    d) The sponsor explicitly budgets the proposed costs in the award notice. Since these costs are specifically set forth in the proposal, it is assumed that the sponsoring agency has approved the costs as direct if the award has been made at the proposed amount. In the case of an "across the board" cut to the proposed budget, it is assumed that the proposed costs have been accepted by the sponsor. In the case of budget cuts to individual cost categories, e.g., personnel, it is the principal investigator's responsibility to notify ORSP of any budget changes made during the award process that eliminated these costs from the awarded budget.

The determining factor in treating F&A costs direct is that they are or will be incurred for a different purpose or in a different circumstance. In most cases, a project that requires more of the same type of costs that are normally treated F&A would not meet the criteria established by the Medical University or by federal sponsors for direct charging the cost.

3.2 Special Circumstances When Charging Normally Treated F&A Costs Direct May Be Appropriate

Administrative and Clerical Salaries

Direct charging administrative and clerical salaries by the Medical University may be appropriate for projects funded by following types of sponsors due to the different purpose for which the award is made. These types of sponsors include:

    1) Industrial/Commercial. Projects sponsored by these organizations are performed at least in part for the benefit of the industrial/commercial sponsor rather than for improving the welfare of the general public. Total costs of the project are the concern of the sponsor and generally, the sponsoring company does not require a detailed budget. Costs are assigned to projects as deemed appropriate by the agreement terms and the Medical University.

    2) Foundations and Not-for-Profit Agencies and Associations.Typically the funding guidelines of these organizations specify the types of costs they will allow to be directly charged to a project.

    3) State Sponsored Agreements or Contracts. The Medical University must comply with State agency regulations and statutory requirements. Consequently, cost must be assigned based on the sponsor's agreement and the award budget.

    4) Training Grants. Since training grants are for a different purpose (training) than a traditional research project, these project budgets may include costs that are normally treated as F&A costs. Training grants usually identify a line item for "institutional allowance" which authorizes direct charging of costs normally treated as F&A if they are reasonable, specifically identified with the project, and allowed by the sponsor's guidelines.

    5) Planning Grants. Research planning grants may be used for preliminary work to determine the feasibility of a proposed line of inquiry, and / or for other activities that will facilitate proposal development. Since planning grants are for a different purpose (planning) than a traditional research project, these projects budgets may include costs that are normally treated as F&A.

Direct charging administrative and clerical salaries by the Medical University may be appropriate also when the special nature of the project requires different administrative and clerical skills than those required for routine departmental administrative activities. Examples include:

    1) Projects that are geographically inaccessible to normal departmental administrative services, for example, a project that takes place in site(s) that is / are remote form the main campus in Charleston.*

    2) Projects with major logistical requirements such as making travel and meeting arrangements (conferences and seminars) for large numbers of participants.*

    3) Large, complex programs such as Program Projects, Center Grants and other sponsored agreements that entail assembling and managing teams of investigators.*

    4) Projects which involve extensive data accumulation and analysis, such as epidemiological studies, clinical trials, and retrospective clinical records studies.*

    5) Projects whose principal focus includes the preparation and production of manuals, large reports, books and monographs,software and multimedia materials (excludes projects that only require routine progress and technical reports).

    6) Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal subject protocols; and other project specific regulatory protocols.

    7) Other Sponsored Activities (not research or instruction). Projects which are beyond the traditional instructional and research responsibilities of an academic unit. These activities primarily provide services beneficial to individuals and groups external to the institution. Examples include activities such as public services, workshops, community development, clinical studies and projects supported by funds passed through by State agencies.

    8) Other. The above categories are not exhaustive. ORSP will review the specific nature of a sponsored agreement on a case-by-case basis to determine if direct charging administrative and clerical salaries is appropriate.

Costs Other Than Administrative and Clerical Salaries

Costs other than administrative and clerical salaries that are normally treated as F&A by the Medical University may be charged direct if incurred for a different circumstance and purpose. The purpose and nature of the cost will be the determining factor. Examples include: postage if the project requires large mailing; animal food or animal cages if the costs are required by the project and are not part of the animal care per diem rate; telephone line charges if the project requires extensive telephone surveys and the lines are dedicated to the project; etc. These guidelines will apply to all sponsored agreements, including traditional research grants such as R01s on a case-by-case basis.

4.0 Grant Budgets, Rebudgeting and Cost Transfers

4.1 Budgets (see also Medical University's Proposal Submission policy)

Budget submissions should be realistic estimates of cost requirements. The estimates should have documented justification in the Principal Investigator's files. The design of the budget should express the intent of the Principal Investigator and should not be designed by an administrator without the Principal Investigator's participation and approval.

4.2 Rebudgeting (see also Medical University's Rebudgeting policy)

Rebudgeting within a grant, after the grant is awarded, is allowed if there is a legitimate need to redirect budgeted costs. All rebudgeting must conform to the sponsoring agency's and/or Medical University's rebudgeting guidelines.

Rebudgeting is not allowed for the purpose of relieving financial pressure on a department's unrestricted budget, or on other grants, or to assign costs that could not otherwise be assigned.

4.3Cost transfers (see also Medical University's Cost Transfer policy)

Cost transfers from one grant to another are permitted in order to link a cost more appropriately with the benefit it is providing.

Cost transfers from one grant to another are not permitted in order to solve funding problems or for other reasons of convenience, A-21 Section C.4.b.

For audit purposes, an adequate explanation for all rebudgeting and cost transfer actions must be on file in the department.

5.0 Direct Cost Allocation Guidelines

Allocation of a Direct Cost Across Two or More Grants

5.1 General Statement

1) This section applies to the allocation of scientific and technical costs, and also to administrative costs that qualify as direct costs under Sections 2.0 and 2.1 above. (Administrative costs are not normally directly charged to grants. Exceptions must meet the standards of Sections 3.1 and 3.2).

2) Whenever a cost can be identified with and charged to a specific grant without administrative difficulty, it should be so charged. The allocation guidelines below apply when identification with a specific grant is administratively impractical.

3) With respect to the allocation of salary and fringe benefit costs across two or more grants, such allocation does not eliminate the requirement for accurate and timely submission of the Position Employee Action Request (PEAR) forms (refer to Effort Reporting policy for details).

5.2 Allocation Guidelines

OMB Circular A-21 states: "If a [direct ]cost benefits two or more [grants] in proportions that can be determined without undue effort or [administrative expense], the cost should be allocated to the [grants] based on the proportional benefit. If a cost benefits two or more [grants] in proportions that cannot be determined because of the interrelationship of the work involved, then...the costs may be allocated or transferred to benefited projects on any reasonable basis..." , A-21 C.4.d (3).

The preceding language from A-21 provides two kinds of flexibility for allocating an allowable direct cost across two or more grants. In these guidelines, they are called the proportional benefit rule and the interrelatedness rule. They are described in more detail below. In general, these two rules are distinguished as follows:

(i) The proportional benefit rule can apply across two or more grants whether or not they are technically and scientifically related, but the distribution of the cost across the grants must be reasonable in proportion to the benefit received .
(ii) The interrelatedness rule can apply only across two or more grants that are scientifically and technically related, and that meet other stipulations, but the distribution of the cost does not have to reflect the distribution of the corresponding benefit.

(In practice, it is likely that the proportional benefit rule will be used more widely, since it does not require demonstration of a scientific and technical relationship among the grants in the designated group.)

When either of these rules is applied, the required close linkage of cost with grant activity, as described in Sections 2.0, 2.1, and 2.2 continues to apply. The process and documentation guidelines described in these sections continue to apply.

Under the provisions of this section, the difference is that these requirements apply to a specified group of grants, not to a single grant. Specifically:

      • The cost in question should be specifically identifiable to the group of grants relatively easily, and with a high degree of accuracy.
      • Credible documentation of this identification must be maintained by the department.
      • Administrative costs cannot normally be charged to such groups of grants unless the costs clearly meet the criteria specified in Section 3.1 and 3.2.

6.0Proportional Benefit Rule

This rule is used when:

    1) the cost in question qualifies as a direct cost under Sections 2.0, 2.1, and 2.2, and

    2) the cost pays for something that benefits two or more grants; and

    3) without undue effort or administrative expense, a proportional distribution of the cost can be devised. For the grants in question, this distribution must reflect, roughly but plausibly, the proportional distribution of the benefits that the cost has paid for. The Principal Investigator, or someone designated by the Principal Investigator must approve the method.

Examples of acceptable methods:

    1) cost distribution of allowable direct costs used by grants A, B, and C, according to each grant's expenditure percentage of the total expenditures in all three grants;

2) distribution of the same cost, according to the each grant's employee FTE share of the total employee FTEs in all three grants;

3) Distribution of administrative costs according to the methods described in a or b above; (Note: such costs must first meet the guidelines described in Sections 3.1 and 3.2 above.)

Other methods may be acceptable and should be discussed with ORSP for approval.

A method is not acceptable if it does not distribute the cost to the sponsored agreements in roughly the same proportion that the benefits are distributed. Examples of unacceptable methods include (also noted in Section 2.3 of these guidelines):

1) rotating charges among grants by month, without a periodic comparison of the charges with actual or estimated proportional benefits to the grants;

2) assigning charges to the grant with the largest remaining balance;

3) in budgets, allocating budgeted costs that are not realistic, or do not represent the Principal Investigator's intent.

7.0 Interrelatedness Rule

This rule applies when a cost is clearly a direct cost for a group of projects, but the cost cannot be assigned by proportional benefit due to the interrelatedness of the work involved. The interrelatedness rule provides greater flexibility in assigning costs, but the conditions for its use are more stringent.

Two conditions must be met. First, the interrelatedness of the grants must be established. Second, the impracticality of charging the cost directly to a single grant, or using the proportional distribution rule, must be established.

1) Identifying an interrelated group of grants. Establishing that a group of grants is "interrelated" is accomplished either by disclosure of scientific overlap when "other support" is described in the initial grant application, or by the documentation of the Principal Investigator, with the approval of the Investigator's academic supervisor. A fundamental criterion of interrelatedness is a close scientific and technical relationship among the grants.

For all grants, federal and non-federal, each of the following conditions must be met in order to establish "interrelationship" among a group of grants:

a) The grants are scientifically and technically related,

b) There is no change in the scope of the individual grants in the group, relative to the scope described in the grant proposals,

c) Establishing interrelationship will not be detrimental to the conduct of work approved under each individual grant,

d) Establishing interrelationship will not be used to circumvent the terms and conditions of an individual grant, and

e) Grants awarded under Public Health Service (PHS) auspices (including all NIH grants) require two additional conditions (see the PHS Grants Policy Statement, pages 7-20, 21):

i) The projects are under the direction of the same Principal Investigator.

ii) All grants in the interrelated group have been funded by the same PHS funding office, for example, by the same Institute, and

f) Approval to use the interrelatedness rule must be obtained from ORSP

Note: For National Science Foundation (NSF) grants, the interrelatedness of grants with more than one Principal Investigator must be approved by appropriate NSF Grants and Program Officers.

2) Distributing interrelated costs. An interrelated cost may be distributed among the grants in an interrelated group on "any reasonable basis." For PHS grants that meet the criteria above, a cost that benefits a set of interrelated grants may be charged to any one or all of them in any proportion that, in the judgment of the investigator, constitutes a "reasonable basis."

 

 

EXHIBIT A - MUSC DIRECT AND FACILITIES AND ADMINISTRATIVE (F&A) COST REFERENCE TABLE

Direct & Indirect Working Group

Velma Graham- Team Coordinator
Carl Brown
Mike Bull
Gerry Garza
Beth Hansell
Jeannine Mathews
Kathryn Meier
John Raymond
Janet Scarborough
Marc Silverstein
Maurice Snook
Marie Townsend

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