Can I charge an item as a direct cost if the sponsoring agency allows it, even if Vanderbilt normally considers that item as an indirect?
No. Awarding agencies are not in a position to make this determination. In fact, NIH has included language in some of their awards indicating this. In the early days before the implementation of the Cost Accounting Standards many institutions adopted the position that if a direct cost normally treated as an indirect cost was budgeted and not cut from the budget during the award process then the cost was an allowable exception to the institutions charging practice. In more recent times, awarding agencies have clarified their position in stating that they are not in a position to determine an institution’s charging practices. The Cost Accounting Standards requires consistent treatment of costs and shifts the burden of proof to the universities.
Related Questions
- Paragraph 8.33(d)(iii) of the CPGs allows an agency to direct source property or services where there is ‘an absence of competition for technical reasons’. What does this include?
- Can I charge an item as a direct cost if the sponsoring agency allows it, even if Vanderbilt normally considers that item as an indirect?
- Can I charge a percentage of the agencys indirect cost rate to the LAUP Program on the quarterly fiscal report?
