Document Downloaded: Wednesday September 16, February 2013 COGR Meeting Thursday Morning Presentation - Cynthia Hope/Jim Luther
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1 Document Downloaded: Wednesday September 16, 2015 February 2013 COGR Meeting Thursday Morning Presentation - Cynthia Hope/Jim Luther Author: Cynthia Hope and James Luther Published Date: 02/23/2013
2 Proposed OMB Uniform Guidance Cost Principles Cindy Hope (UA) Jim Luther (Duke) February 21, 2013
3 Agenda Subchapter F: Cost Principles Background and Overview Good, Bad, Unknown Compensation Personal Services F&A
4 Background and Overview Cost Principles Subchapter F (Pages ) General themes Allocability, Reasonableness, Consistency remains Terminology Inconsistency: Grants, coop agreements, contracts, etc. Non profit, Educational Universities, etc.
5 Good Eliminated for grants/cooperative agreements (not clear on contracts) Appendix A CASB's Cost Accounting Standards Appendix B CASB's Disclosure Statement (DS 2) Computers: non capital computers can be direct charged if allocable; does not need to be solely dedicated (Pg123/C 31) Travel Cost: Temporary dependent care costs allowable but must be consistent & only for the time period of travel, etc. (Pg134/C 53(C))
6 Bad GOOD MTDC Exclusions: Awarding agency can make determination (Pg83/616e) Eliminated (C4): Where the purchase of equipment under a sponsored agreement, the amounts thus authorized for such purchases are assignable to the sponsored agreement regardless of the use that may subsequently be made of the equipment
7 Unknown GOOD Eliminated: The dual role of students engaged in research and the resulting benefits to sponsored agreements are fundamental to the research effort Direct Charge of Admin and Clerical Personnel (Pg79/615(d)) Removed Major Project and greater than routine level but retained explicitly included in the budget Meetings: Allowable if purpose is the dissemination of technical information beyond the recipient entity (Pg123/C 32) Unused Materials or Supplies: residual inventory (including computers) <$5k may be retained (Pg123/C 31(6)) Sponsor use of negotiated F&A rates: Inconsistency as to whether OMB must approve (Pg24/204(B)) and Pg80/616(1))) Equipment definition now includes Software Costs: useful life >1 year and exceeds the lesser of cap level or $5k (Pg109/C18(B)))
8 Compensation Personal Services GOOD Compensation Personal Services (OMB A 21 J.10 moved to C10 (page 89)) Inconsistent nods to previous responses and OIGs Related and Incidental Activities: Added language to allow for developing and maintaining protocols managing substances managing project specific data (Pg90) Eliminated: J.10.c(1)f: requirement for independent internal evaluation Examples of Acceptable Methods for Payroll Distribution Extra Service Pay (Pg91/8(b)) Requires definition of full time workload (Pg91/8(b)(2))
9 Compensation Personal Services GOOD Standards for Documentation of Personnel Expenses (Pg93/(9)) Effort certification Employees working solely on one award require semiannual certification (Pg93/(9)(B))) Certified reports Reports may be integrated with or separate from the payroll distribution system; where integrated, duplication of records should not be necessary. (Pg93/(9)(C) Significant changes identified in a timely manner shortterm fluctuations (one to two months) need not be considered If based on budgets, Distribution percentages are revised at least quarterly what documentation needed?
10 F&A Costs Identification and Assignment Rate extensions: rates can be extended for up to 4 years (Pg83/616(e)) No clarity on type of rate extension Indirect cost rate: Institutions can use 10% rate without rate calculation for up to 4 years (Pg83)(616(e)) Utility Cost Adjustment / Special Cost Studies Eliminated but research space can be weighted with effective square footage with relative utilization index or sub building metering (Pg 200/IV(B)c)
11 F&A Costs Identification and Assignment Eliminated Lease purchase analysis (J.26b(1)) Documentation to support use of reimbursed depreciation Institutions should not change their accounting or cost allocation methods if the effect is to: (i) change the charging of a particular type of cost from F&A to direct, (G.8(d)) Negotiation and approval of indirect rates: Determinations should include a description of any adjustments, the actual amount, both dollar and percentage adjusted, and the reason for making adjustments
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