Grant Budgeting
The University is tax exempt in its capacity as a 501 [c] 3 not-for-profit educational institution.
Employer Identification Number (EIN) is 63-0477348.
Data Universal Numbering System (DUNS) assigned by Dun & Bradstreet for credit rating purposes is 172750234.
Commercial and Governmental Entity Code (CAGE Code) assigned to USA by the Defense Logistics Information Service is 1NZ96.
The University’s National Science Foundation identification number is 0010579000.
The University's U.S. Department of Health and Human Services (DHHS) EIN number is 1630477348A1.
The University is located within Alabama’s First District [Mobile, Baldwin, Washington, Clarke, Monroe, Escambia].
Official Signing for Applicant Organization (Authorized Organizational Representative):
Dr. Russ Lea
Vice President for Research
Office of Research Administration
University of South Alabama
307 University Blvd., AD200
Mobile, AL 36688
Tel: 251/460-6333
FAX: 251/460-7955
Email: awards@usouthal.edu
Direct Charges / OMB A-21
Federal Circular A-21 regulates which items can be charged as a direct charge to grants and which items are included as part of the F & A expense. This circular defines the terms "direct charge" and "F & A expense" in grants. Examples of items that are generally considered to be F & A expense are secretarial salary, clerical salary, office supplies, copies, printing, computers, and local telephone lines. The government"s position is that when we negotiate our F & A rate, it includes all of these things so if we make a direct charge for one of these items, we are, in effect, double billing the government.
There are only two exceptions to this regulation. The first is if a project meets the government's definition of major program, it may be allowable to convert some F & A expense to a direct charge. It should be noted that very few programs at the University are defined as "Major Programs". This is decided on a case by case basis using the guidelines found in Appendix C of Circular A-21. To meet the exception the project must require more than the normal amount of the type of charge being considered. The second exception is if it is included as a line item in the proposal and a justification is included in the proposal explaining why this is an unlike circumstance. An unlike circumstance is something that makes this situation different than what would usually be the case for grants. For example, a local telephone line is normally considered to be F & A, but if the grant is a polling grant and has a large number of callers, the local telephone lines can be justified as a direct charge under the unlike circumstances exception, since many more lines would be required than would be under normal grant circumstances.
Please keep these regulations in mind when submitting your proposals. If you include items as direct charges that are normally part of the F & A expense please include the justification so that your proposal will not be delayed.
Memo from Office of Grants and Contracts Accounting, November 2006
From the NSF Grant Proposal Guide:
"In most circumstances, particularly for institutions of higher education, salaries of administrative or clerical staff are included as part of indirect costs (also known as Facilities and Administrative Costs (F&A) for Colleges and Universities). Salaries of administrative or clerical staff may be requested as direct costs, however, for a project requiring an extensive amount of administrative or clerical support and where these costs can be readily and specifically identified with the project with a high degree of accuracy. Salaries for administrative or clerical staff shall be budgeted as a direct cost only if this type of cost is consistently treated as a direct cost in like circumstances for all other projects and cost objectives. The circumstances for requiring direct charging of these services must be clearly described in the budget justification. Such costs, if not clearly justified, may be deleted by NSF."
From OMB A-21 Section F. 6. b.
"2) The salaries of administrative and clerical staff should normally be treated as F&A 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. "Major project" is defined as a project that requires an extensive amount of administrative or clerical support, which is significantly greater than the routine level of such services provided by academic departments. Some examples of major projects are described in Exhibit C.
3) Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs."
OMB A-21 Exhibit C
"Exhibit C -- Examples of "major project" where direct charging of administrative or clerical staff salaries 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 clinical records studies).
Projects that require making travel and meeting arrangements for large numbers 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 research vessels, radio astronomy projects, and other research fields sites that are remote from campus.
Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.
These examples are not exhaustive nor are they intended to imply that direct charging of administrative or clerical salaries would always be appropriate for the situations illustrated in the examples. For instance, the examples would be appropriate when the costs of such activities are incurred in unlike circumstances, i.e., the actual activities charged direct are not the same as the actual activities normally included in the institution's facilities and administrative (F&A) cost pools or, if the same, the indirect activity costs are immaterial in amount. It would be inappropriate to charge the cost of such activities directly to specific sponsored agreements if, in similar circumstances, the costs of performing the same type of activity for other sponsored agreements were included as allocable costs in the institution's F&A cost pools. Application of negotiated predetermined F&A cost rates may also be inappropriate if such activity costs charged directly were not provided for in the allocation base that was used to determine the predetermined F&A cost rates."
A “Program Project” as defined by NIH
"A research program project (P01) award is for the support of a broadly based multidisciplinary or multifaceted research program which has a well-defined major objective or central theme. It is directed toward a range of scientific questions having a central research focus in contrast to the more narrow thrust of the traditional research project (R01). The program project involves the organized efforts of groups whose members are conducting research designed to elucidate the various aspects or components of the central theme. Each research project is usually under the leadership of a different experienced investigator and should contribute to the common theme of the total research effort. Collectively, these projects should demonstrate essential elements of unity and interdependence and result in a greater contribution to program goals than would occur if each project were pursued individually. It is expected that most of the collaborating scientists will be independent investigators. Thus, support of one senior investigator and several postdoctoral or research associate-level scientists as project leaders is not appropriate. The program project grant is not intended to be a vehicle for departmental research support. In most cases, several departments should be represented."
If you have any questions, please contact Steve Croft, OSP Associate Director, scroft@usouthal.edu, 460-6456.
Cost Accounting Policies
The Office of Grants and Contracts Accounting website maintains the following information:
- Budgeting
- Regulatory Issues
- Grant Writing
- Project Closeouts
- Cost Principles
- Minority Business
- Cost Sharing
- Cost Transfers
- Service Centers
- Program Income
- Reporting Responsibilities
- Roles and Responsibilities
- Project Transfers
- Proposal Routing
- Effort Reporting
F&A Cost Rates
The Office of Grants and Contracts Accounting website maintains the following information:
- Facilities & Administrative (F&A) Cost Rates
- Modifiied Total Direct Cost (MTDC) Base
- Fringe Benefits
