Guide to Allowable CostsOffice of Grant and Contract Services
Guide to Allowable Costs on Sponsored Projects
The following guide is to assist Principal Investigators (PI) in conjunction with Department Chairs, Administrative
Assistants, Grant and Contract Services (GCS) personnel, and Office of Grant Accounting (GCA) personnel, to
understand compliance with University, State, and Federal policies for charging costs to Sponsored Projects
The University of Texas at Arlington’s accounting system places considerable authority and responsibility directly with the
Principal Investigator and their respective departments. Such a system requires the development of significant expertise
at the department level and relies heavily upon the compliance of principal investigators, administrative assistants and
those who create accounting documents.
Charges on grant accounts are certified by Principal Investigators to confirm the appropriateness of the expense each
month via the Statement of Account. Pro Cards allow for expenditures that are confirmed after the fact and may already
be paid for by the University. Even though Pro Cards are intended to increase the ease of use for charging expenses to
grant accounts, there is an increased audit risk and therefore Pro Card statements are reviewed with more scrutiny to
ensure costs are appropriately documented.
This guide is based upon best practices among other universities and federal audit findings for determining allowability of
costs on federally funded projects. The guide describes the normal treatment of costs and does not claim absolute
allowability for cost items as specific situations may warrant exceptions to the treatment of costs. This guide however, is
intended to clarify the rationale for items of costs to better assist PIs, department staff, GCS and GCA to work together
and ensure compliance.
The Office of Grant and Contract Services welcomes all questions regarding budgeting, appropriate costs, compliance
with various policies, and the terms and conditions that may affect sponsored projects. Grant and Contract Services may
be contacted at extension 22105 or via email at firstname.lastname@example.org.
TABLE OF CONTENTS
I. Basic Principles and Definitions 3
A. General Philosophy of A-21 3
A.1 Reasonableness 3
A.2 Allocability 3
A.3 Allowability 4
B. Definition of Direct Costs 4
C. Definition of Indirect Costs 4
D. Definition of Unallowable Costs 4
E. Consistent Treatment of Costs 5
F. Cost Sharing, In-Kind, Matching 5
G. Documentation 6
II. Example Treatment and Types of Costs 6
A. Administrative and Clerical Salaries 6
A.1 OMB Clarification to Administrative Salaries 6
A.2 UT Arlington Interpretation and Procedures for Admin. Salaries 7
B. Costs Normally Treated as Direct Costs 8
C. Costs Normally Treated as Indirect Costs 8
III. Budget Preparation and Post Award Rebudgeting 9
A. Budget Preparation 9
B. Post Award Rebudgeting/Expense Transfers 10
C. Unacceptable Practices 10
IV. Roles and Responsibilities 10
A. Principal Investigator 10
B. Grant and Contract Services 10
C. Chair/Dean/Director 10
D. College/Department Administration 11
E. Grant and Contract Accounting 11
V. Record Retention 11
I. BASIC PRINCIPLES AND DEFINITIONS
A. General Philosophy of OMB Circular A-21
The Office of Management and Budget developed circular A-21 (now 2 CFR, Part 220) to describe the treatment of
costs on sponsored project activities (direct and indirect) that can be billed to the federal government. A-21 applies to
all federally funded projects including federal funding through a non-federal agency.
From OMB Circular A-21, Section C.: “The recipient institution is responsible for ensuring that costs charged to a
sponsored agreement are allowable, allocable, and reasonable...”
A.1. Reasonable (includes Necessity)
The basis for determining reasonableness is that a cost would withstand public scrutiny -- i.e., objective
individuals not affiliated with the institution would agree that a cost is appropriate on a sponsored project.
A reasonable cost is one where the nature and amount of the goods or services acquired reflects the
action that a prudent person would have taken under the circumstances prevailing at the time the
decision was made to incur the good or service.
Typical tests to determine if a cost is Reasonable:
- Whether the type of cost is generally recognized as necessary for the operation and performance of the sponsored project.
- Whether the purchaser acted with due diligence in a given circumstance relative to their responsibilities and role to UT Arlington and the general public.
- Whether the actions taken by the purchaser were consistent with established UT Arlingtonpolicies and practices applicable to the goals of the sponsored project.
- A piece of equipment purchased near the expiration of the project. Is it reasonable to purchase a lab computer 15 days before project expiration when the final work, report or project objectives could be completed using existing or alternative resources? Could a reasonable justification be provided to warrant the necessity of a piece of equipment that is perceived to benefit the project for only 15 days? Typically equipment is budgeted and purchased at the beginning of research projects.
A cost is applicable to a particular sponsored project to the extent in which the sponsored project benefits
from the expense. Expenditures should be allocated to accounts in accordance to the benefit or use to
be expected from the good or service.
A cost is allocable to a sponsored project if:
- It is incurred solely to advance the work under the sponsored project.
- It benefits a sponsored project in a proportion that can be approximated using reasonable methods.
- It is necessary and reasonable to the extent that is assignable to the sponsored project.
From OMB Circular A-21, C.4.d.(3): “If a cost benefits two or more grants or contracts in proportions that
can be determined without undue effort, 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...”
Special equipment or other unique items specifically budgeted and authorized in a sponsored project may
be 100% allocable to that project regardless of the subsequent use of the special equipment or unique
item. Equipment purchased or transferred using government funds may be subject to other terms and
conditions or other agreements that set the priority of use of equipment to specific parties. This can be a
reasonable basis for determining 100% of a cost as being allocable to the sponsored project in which the
equipment or item was specifically budgeted.
A-21 provides two kinds of flexibility for allocating an allowable direct cost across two or more grants:
1). The proportional benefit rule can apply across two or more grants whether or not they are technically and scientifically related, but the distribution of costs across grants must correspond roughly to the distribution of the corresponding benefit.
2). The interrelatedness rule can apply only across two or more grants that are scientifically and technically related, but the distribution of the cost does not have to reflect the distribution of the corresponding benefit (because the proportional benefit cannot be measured.) Interrelatedness must be documented by the PI when applying this rule to multiple projects.
A direct cost is allowable on a federal grant or contract if it is:
- reasonable and necessary in accordance with see section A.1.
- allocable to the sponsored project in accordance with section A.2.
- consistently treated as a direct cost in accordance with sections B and D.
- conforming to the limitations or exclusions in OMB A-21 section J, the award terms and conditions, and University policies.
From OMB Circular A-21, Section D.1: “Direct costs are those costs that can be identified specifically with a
particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly
assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same
purpose in like circumstances must be treated consistently as either direct or 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 for all activities of the institution.”
A direct cost is one where a specific grant or contract gains explicit benefit from that cost for a specific
programmatic purpose. Examples of common direct costs expenses are: salaries, wages, fringe benefits,
materials and supplies, equipment, STEM tuition, travel, etc.
C. Definition of Indirect Costs
From OMB Circular A-21, Section E.1.: “Indirect costs are those costs 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. At educational institutions such costs normally are
classified under the following indirect cost categories: depreciation and use allowances, general administration
and general expenses, sponsored projects administration expenses, operation and maintenance expenses,
library expenses, departmental administration expenses, and student administration and services.”
Indirect costs are infrastructure costs of the University needed to support the programs of the institution, including
research and other sponsored programs. Building depreciation, maintenance costs, the cost of electricity and
heat, accounting services, personnel services, departmental administration, purchasing, and human subjects
administration are examples of indirect costs. Sponsored projects in which the university’s full IDC rate is limited
or reduced due to sponsor policies can allow for the university to recoup this loss through direct charging of costs
normally considered indirect.
D. Definition of Unallowable Costs
UT Arlington defines unallowable costs as those expenses which are not reimbursable under the terms
and conditions of federally sponsored awards or agreements and/or those specifically identified as
unallowable in Section J of OMB Circular A-21.
Typically, unallowable costs include:
1. Advertising-including radio, television, exhibits, promotional items, production of internal newsletters and
magazines. Advertising costs for patient recruitment and fellowship and training programs are allowable.
Revised 6/29/2012 5
2. Alcoholic beverages
3. Graduation ceremonies and other commencement expenses
4. Bad debt expense
5. Internal allocation of interest
6. Fund raising
7. Fines and penalties
8. Costs of professional investment advice
9. Costs of faculty or administrative housing
10. Personal use of institutional automobiles or other property and services
11. Club and civic and community memberships
12. Alumni activities
14. Public relations
15. Medical malpractice insurance
16. Meals and travel associated with lobbying, fund raising, alumni activities
17. Entertainment for holidays, retirements and other costs for recruiting, entertaining, and tickets to events
18. Student activities
19. Unrecovered costs (losses) of service centers
20. Costs for prosecuting claims against the federal government
21. Overdrafts on restricted funds
22. Contributions and donations
E. Consistent Treatment of Costs
Consistent treatment of costs is specifically required by OMB Circular A-21 to assure that the same types of costs
are not charged to grants and contracts both as direct and as indirect costs. Consistency means that costs
incurred for the same purpose in like circumstances must be treated uniformly either as direct costs or as indirect
costs. Thus, if certain costs, such as office supplies and postage, are treated as indirect costs, the same
types of costs cannot be directly charged to programs, unless the circumstances related to a particular
program or activity are clearly different from the normal operations of the institution. The consistency
requirement applies to the institution as a whole. Costs must be classified consistently across all the departments
and other organizational units of the university. For example, if technicians' salaries are charged directly to grants
and contracts, the institution would need to treat the salaries of staff performing comparable work on nonsponsored
programs as direct costs of those programs and exclude these costs from its indirect cost pool.
F. Cost-Sharing, In-Kind, Matching Expenses
All cost sharing costs on federally funded projects must meet the requirements of A-21 just as if they were directly
charged to the sponsored projects. Costs determined unallowable under A-21 as direct costs on a particular
federally-funded grant or contract cannot be cost shared on that award. Costs that are not allowable based on
specific sponsor regulations may be allowable as cost sharing if these costs are not disallowed under A-21.
All costs on federal sponsored projects must be allowable, allocable and reasonable in addition to being verified
by someone in the position to know the appropriateness of the charge (e.g., the PI). Appropriate documentation
must be maintained by the Department in accordance with University Policy.
II. EXAMPLE TREATMENT AND TYPES OF COSTS
The enforcement, interpretation and methods for determining cost allowability or treatment of costs are based on
results of many audit interpretations, best practices among other Universities, and conformance to University
policies and systems. Following are example “questionable costs
Further guidance and an example listing of costs treated as direct or indirect can also be found at
A. ADMINISTRATIVE AND CLERICAL STAFF SALARIES
From OMB Circular A-21, Section F.6.b.: “The salaries of administrative and clerical staff should normally be
treated as indirect costs. Direct charging of these costs may be appropriate where a major project or activity
explicitly budgets for administrative or clerical services and individuals involved can be specifically identified with
the project or activity.”
A.1 OMB Clarification, Issued July 13, 1994
Circular A-21 says that the salaries of administrative and clerical staff should normally be treated as indirect
costs. This section goes on to say that direct charging of these costs may be appropriate where a major project
or activity explicitly budgets for administrative or clerical services and the individuals involved can be specifically
identified with the project or activity. What is the intent of this provision and under what circumstances may these
costs be directly charged to sponsored agreements?”
“This provision is intended to establish the principle that the salaries of administrative and clerical staff should
usually be treated as indirect costs, but that direct charging of these costs may be appropriate where the nature of
the work performed under a particular project requires an extensive amount of administrative or clerical support
which is significantly greater than the routine level of such services provided by academic departments.
The costs would need to meet the general criteria for direct charging i.e., be identified specifically with a particular
sponsored project... relatively easily with a high degree of accuracy, and the special circumstances requiring
direct charging of the services would need to be justified to the satisfaction of the Office of Grant and
Contract Services and the sponsoring agency.”
The following examples are illustrative of circumstances where direct charging the salaries of administrative or
clerical staff may be appropriate.
- Large, complex programs, such as General Clinical Research Centers, Primate Centers, Program Projects,environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
- Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging,searching literature, and reporting, such as epidemiological studies, clinical trials, and retrospective clinicalrecords studies.
- Projects that require making travel and meeting arrangements for a large number of participants, such as conferences and seminars.
- Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
- Projects that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels, radio astronomy projects, and other research field sites that are remote from the campus.
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocol, IRB preparations and/or other project-specific regulatory protocols; and multiple project-related investigator coordination and communications.”
salaries would always be appropriate for the situations illustrated in the examples. Where direct charges for
administrative and clerical salaries are made, care must be exercised to assume that costs incurred for the same
purpose in like circumstances are consistently treated as direct costs for all activities. This should be
accomplished by ensuring the costs are directly to the appropriate activities.”
A.2 UT ARLINGTON Interpretation and Implementation Procedures for Administrative Costs
1. Major Activity
The dollar value of a grant or contract is just one factor in designating a specific program or project as “major.”
The scope of the project, type of effort, and degree of effort involved must be considered. Administrative costs
may be allowable on a “major project” provided they
a. are specifically associated with the work of the grant or contract, either as part of an unusually large or
complex activity that requires separate administrative support, or an administrative effort that is required
to complete the specific and distinctive requirements of a particular grant or contract or group of grants or
b. represent extensive work, significantly more than the routine level;
c. are a realistic reflection, through appropriate documentation, of planned or actual effort;
For example, if a person spends 50% time working with UTA’s financial accounting system to process
expenditures on multiple sponsored project accounts and vouchers for a research department, this represents
a significant level of effort, but does not make a direct contribution to the programmatic success of the
sponsored project. Therefore, the function being performed is an indirect function and considered to be an
2. Specific Identification
Individuals whose salaries and related fringe benefits are paid from a grant or contract must have
responsibilities identified specifically with the work of the project (e.g., administrative work specifically related
to the distinctive scientific and technical requirements of the grant or contract.) Supporting certification and
time and effort reports will be required.
The salaries and related fringe benefits of individuals whose responsibilities do not meet these standards
cannot be charged directly to a grant or contract without the approval of the UT ARLINGTON dean/director of
the college/school/institute/center and the appropriate Office of Grant and Contract Services specialist. OMB
has provided examples of the kinds of circumstances where these costs can be directly charged.
Responsibilities that duplicate normal departmental administrative functions such as proposal preparation,
accounting, payroll, purchasing, etc. cannot be charged directly to a grant. The cost of administrative
work such as library searches, filing, and manuscript preparation would not be considered allowable
direct charges because such work is common across many grants. Such costs may support grant or
contract activity, but they are classified by A-21 as indirect costs because they do not meet A-21's
“specific identification” standard.
To comply with A-21, the percent of effort, salaries, and fringe benefits of administrative and clerical
positions must be specifically included in the proposal budget and be clearly explained.
B. Costs Normally Treated as Direct Costs
From OMB Circular A-21, D.1.: “Direct costs are those costs that can be identified specifically with a particular
sponsored project...or that can be assigned to [such activity] relatively easily with a high degree of accuracy.”
This policy limits direct charges to a federally-funded grant or contract that directly support the purpose and
activity of the grant or contract. The following are examples of acceptable direct costs that meet A-21 guidelines if
identifiable to a particular sponsored project:
- Supplies and Operation costs:
and zip storage), aluminum foil and plastic wrap for packaging and preserving specimens, animals, animal care
costs, computer costs, travel costs, technical and scientific equipment (and related maintenance agreements
under $5,000), and specialized shop costs.
- Communication/Shipping/Phone Costs:
the project). Dedicated cell phones/telephone lines to conduct surveys or clinical subject contact lines are
allowable as these are unlike circumstances to routine business purposes.
Rationale: These costs can be directly assigned to a particular project relatively easily and with a high
degree of accuracy. Office telephones are usually used for multiple purposes (instruction, administration
and research), and cannot be assigned to a specific activity or project easily.
- Printing/Dissemination Costs:
required for poster or publication preparation (posterboard, photographic supplies, color paper) and page
Direct charges should be identified with the work of a particular award or group of awards. Appropriate
documentation must be maintained by the PI’s department to ensure the cost is identifiable with activity in the
grant or contract. Additionally, all electronic vouchers should fully justify and link charges to the activity of the
grant or contract. Documentation linking a cost to an activity should be done by someone in a position to know
this linkage (e.g., the person making the telephone call, the person taking lab supplies from a common stock,
etc.). A manual log, specific access codes, or assignment of charges by the project director on the monthly
telephone bill are all acceptable methods for documenting telephone toll charges.
C. Costs Normally Treated as Indirect Costs
From OMB Circular A-21, F. 6.b.: ““Items such as office supplies, postage, local telephone costs, and
memberships shall normally be treated as indirect costs.”
General office supplies (paper, pencils, pens, accent markers, all purpose notebooks, binders, file folders, etc.)
normally cannot be considered an allowable direct cost on a grant or contract. However, exceptions may be
dictated by the nature and/or demand of the research project that could make such charges allowable when
appropriate justification has been provided.
Proposal budgets should include a detailed explanation of, and justification for, any purchase of administrative or
office supplies. Requests for the addition of new spending lines on an existing award for the purchase of
previously unbudgeted administrative or office supplies will be considered by the Office of Grant and Contract
Services upon appropriate justification, including cost estimate.
Postage is ordinarily an indirect cost of sponsored activities. However, if a particular program has a special need
for an extraordinary amount of postage because of the mailing of hundreds of survey questionnaires, for example,
then it would be appropriate to charge that program directly for the postage related to the questionnaires.
Local Telephone Costs and Monthly Rental
Local telephone and monthly rental charges are not allowable direct costs unless specifically requested and
justified in the proposal and approved by the sponsor. An example of allowable monthly rental costs would be
those for projects funded for telephone surveys as a major component of the research or sponsored activity.
Memberships are not normally allowable direct costs unless the sponsor requires the membership for the
performance of the project and the cost is specifically approved in the award budget by the sponsor. The basis of
this cost being an indirect cost is because it is not easily identifiable to a specific project or University function.
The reference material benefits the University, Department, colleagues, and multiple projects in such a way that it
cannot be allocated with a high degree of accuracy.
In the infrequent occurrences where memberships are allowable direct expenses, special care should be taken to
assure that none of the membership fee is used to support lobbying expenses.
Photocopying costs cannot be charged directly to a grant or contract except those costs directly related to a
programmatic activity (e.g., the printing of surveys and questionnaires).
Office supplies drawn from common stock will be considered unallowable as a direct cost unless sufficient written
documentation is kept regarding their direct applicability to the sponsored project.
Faculty Consulting Within the Home Department
Addressed in OMB Circular A-21, faculty are expected to consult on University of Texas at Arlington projects as
part of their University faculty appointment but supplemental compensation related to consulting services may be
allowable in certain, extenuating circumstances:
“Since intra university consulting is assumed to be undertaken as a university obligation requiring no compensation in
addition to full time base salary, the principle also applies to faculty members who function as consultants or
otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution.
However, in unusual cases where consultation is across departmental lines or involves a separate or remote
operation, and the work performed by the consultant is in addition to his regular departmental load, any charges for
such work representing extra compensation above the base salary are allowable provided that such consulting
arrangements are specifically provided for in the agreement or approved in writing by the sponsoring agency.”
III. BUDGET PREPARATION and POST AWARD REBUDGETING
A. BUDGET PREPARATION
To charge expenses normally considered indirect costs on federally sponsored projects, it is recommended to list
the costs explicitly in the University proposed budget, which is intended to become the sponsor approved budget.
This documentation is the number one consideration for allowability on “questionable items”. The preferred test
for allowability is sponsor approval. The proposed budget is the starting point for identifying “questionalbe” items
normally considered indirect costs as direct costs. These items should be justified in the budget and budget
The following example justifications and considerations should be in mind during budget preparation:
- Because all projects require a certain level of account reconciliation, correspondence, communications,and office expenses, how do the proposed costs differ from the standard level of department assistanceprovided to all projects?
- The job title may imply that the effort is dedicated to administrative purposes. Is the nature of the work different from the general administrative work conducted for all sponsored projects? Are the charges necessary to meet the technical or programmatic needs of the project versus the administrative needs?
- The term “office supplies” or “other” are vague and may imply that the items are being used for administrative purposes. How will the items be used to meet the technical needs of the project? Explain their relevance to technical aspects of the project above the normal expectation of these costs being provided by the department.
- Can the proposed charges be easily and accurately documented as appropriate to the project and how will this be done (allocability)?B. POST AWARD REBUDGETING/EXPENSE TRANSFERS
B. POST AWARD REBUDGETING/EXPENSE TRANSFERSIt is expected that costs will be posted to the correct grant or contract at the time of purchase. However, in the
event the transfer of a charge is required, the transfer should be requested as soon as the need for correction is
identified. Justification must be provided to GCS for the transfer. Additional justification may be needed by GCS
if the expense transfer is requested 90 days or more after the accounting date.
Likewise, it is expected that the budgets submitted to sponsors accurately reflect projected project expenses. The
course of research may alter as research can be unpredictable in nature. The need to rebudget line items may be
necessary to accommodate the performance of the research. However, a change in the scope of work often
requires sponsor prior approval which may require major revisions to the approved budget. Rebudgeting should
never be used to circumvent the integrity of the budgeting process.
When considering items normally treated as direct costs, as an exception, local rebudgeting authority may be
approved by GCS and can substitute for explicit sponsor approval in those instances where 1) the terms of the
award allow rebudgeting flexibility and 2) the need for the expense was not contemplated at the time the original
budget was prepared. The PI and GCS will use their judgment as to when to approach the sponsor for specific
Each grant and contract account is inactivated 30 days past the project end date. After that time, only charges
against open purchase orders can be posted without intervention by GCS staff. Normally, the final financial report
must be filed with the sponsor within 90 days of the project end date. Therefore, approved cost transfers should
be made no later than 45 days past the award period end date.
C. UNACCEPTABLE PRACTICES:
- The following are unacceptable practices and justifications for charging expenditures to federally funded
- Charging costs to spend remaining balances.
- Rotating charges among projects (see allocability)
- Applying a tax to projects to distribute clerical and administrative expenses within the department.
- Charging more than the actual cost of an item or service.
- “Rainy Day Purchases” where a cost may be beneficial to other projects after the project end date. The cost must benefit the project during the period of performance or for dissemination of results.
- All sponsored project expenditures may not be shifted to other sponsored projects in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law, by terms of the sponsored project, or for other reasons of convenience.
- Any costs allocable to activities sponsored by industry, foreign or state governments, or costs applicable to the University, may not be shifted to federally sponsored projects.
IV. ROLES AND RESPONSIBILITIES (related to allowable costs)
A. Principal Investigator (PI)
Prepares proposal in accordance with solicitation guidelines, estimates costs, writes budget narrative and
justification for costs, administers award in accordance with A-21 cost principles.
B. Grant and Contract Services (GCS)
Provides proposal budget development support, advises PI’s and project directors regarding allowability of costs,
ensures adherence to sponsor and institutional policies and guidelines. Approval of budget transfers, budget
setup and expenditure transfers for journal entry by Grant and Contract Accounting.
Approves the department commitment to the sponsored project (e.g., cost-sharing, space, effort).
D. College/Department Administration
Monitors costs applied to sponsored projects, assists PI and accounting personnel in processing of charges and
ensures adequate justification is provided by the PI in accordance with A-21 and University policies.
E. Grant and Contract Accounting (GCA)
Enter and approve budget transfers, budget setup and expenditure transfers in the DEFINE accounting system.
V. RECORD RETENTION
Documentation for financial records must be maintained for a minimum of three years following the official closing and
sponsor acceptance of the final reports (OMB Circular A-110). All documentation in the University's financial
accounting system is acceptable when complete.