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The
Cost Principles: OMB Circular A-21
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Examples
of A-21 Cost Principles
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The
following hypothetical situation illustrates the cost
principles
defined in OMB Circular A-21:
ALLOWABILITY
You have a research grant from the National Science
Foundation to study changing climate patterns. The
project includes participating in a conference in
Seattle. A graduate student in your lab has been invited
to present a paper at this conference. There are no
prohibitions against travel on the grant, so the student's
travel costs are ALLOWABLE.
At the conference, your student has dinner with a
friend and orders wine (the student is, of course,
of legal drinking age in the state of Washington).
The cost of the wine (plus tax and tip) is an UNALLOWABLE
cost (as identified in A-21), and that part of the
bill may NOT be charged to the Government. The University
of Rochester can reimburse the student for this portion
of the dinner expense, but the money must come from
non-sponsored funds, and be recorded in the University's
accounting system as an UNALLOWABLE
cost.
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ALLOCABILITY
The ALLOCABILITY cost principle stipulates that any
expense paid by a project must benefit that project.
This particular conference focuses on the "El
Nino" effect on global climate. Your student
will present her paper and interact with colleagues
from other academic institutions. The trip will benefit
the project, and the travel costs are therefore ALLOCABLE
to the project.
Without some documentation, the University's Finance
Department (or an internal or external auditor) might
question the ALLOCABILITY of this expense to your
project. In a case like this, when your department
submits expense reports for reimbursement, the package
should include the conference agenda or other documentation
to support the relationship between the travel and
the project which paid for it.
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REASONABLENESS
Your student was feeling rather good after her presentation
and decided to celebrate in a BIG way. She brings
back receipts showing that the cost of her final dinner
in Seattle, exclusive of the wine, was $147. per person.
Even though the trip was allowable and allocable,
that cost is not REASONABLE. The cost
principle of REASONABLENESS stipulates that costs
will be reimbursed only if a prudent person would
have paid this amount. If not, the expense may not
be charged to the Government.
The University of Rochester also has an "actual
and reasonable" requirement for travel expenses
(where a traveler is not using "per diem"
reimbursement). Your student may therefore not be
fully reimbursed for this expense by the University
either, although she can be reimbursed for a lesser,
reasonable amount.
Questions as to whether a particular expense is reasonable
or not may be referred to the department head and
/ or the Finance Department. See the Finance
Department's Travel and Conference Policies
for further detail.
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CONSISTENCY
Because your student's participation in this conference
directly benefited your NSF project, reasonable travel
costs should be charged DIRECTLY to that project.
Other expenses incurred in similar circumstances in
other parts of the University should also be charged
directly to the appropriate projects.
If a trip that benefits a specific project is charged
INDIRECTLY, or such expenses are charged to departmental
funds, a portion of those costs could end up in the
University's indirect cost pools.
Pooled research expenses are then charged to ALL sponsors
through the application of the University's indirect
cost rates. Therefore, trips benefiting specific projects
should rarely be charged to departmental funds. This
inconsistency may, in extreme cases, violate Cost
Accounting Standards, and may lead to unfair "double
charging."
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