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This section provides supplemental interpretation of federal regulations contained in Circular A-21 concerning charging specific types of administrative costs to federal research and training grants. This interpretation will be used to assess the appropriateness of charges on research and training grants administered by Harvard.
Books
Subscriptions
General Office Supplies
Copier Charges, Copy Cards
Dues and Memberships
Local Travel Costs (Meals, Parking)
Telecommunications, Cellular Phones, Internet Access
Postage, Express Delivery
Other Expenses
Special Considerations for Federal Training Grants
The NIH Grants Policy 11-40 states: "If an organization has a library, then books and journals should generally be provided as part of normal library services and treated as F&A costs rather than being directly charged."
The University's interpretation of this NIH policy is that books may normally not be charged directly to sponsored research projects unless the purchase meets all three tests of unlike circumstances identified above, namely:
- Unlike circumstances exist, that is, this sponsored award is different from typical sponsored awards at Harvard.
- The book cost can be associated with the sponsored project with a high degree of accuracy.
- The awarding agency has approved charging the book cost as a direct cost in the awarded budget.
In addition, the Principal Investigator must provide a written justification supporting the direct charge to the research project.
Examples of allowable book or reprint or copy of article charges:
- Purchase of software, equipment or similar manual to improve efficiency and/or results of PI or lab personnel use of software or equipment used in the specific research project.
- Book associated with a specific research technique or aspect of the research project that will introduce efficiencies to the research, improve quality of results, to get better results from a specific piece of research equipment or from a research experiment.
- Books not available from the library or from other sources or specific books needed so often that a library copy is not sufficient.
Examples of unallowable book charges:
- General or reference texts, including medical dictionaries.
- General software, e.g. a widely used statistical package and associated manuals that will benefit multiple activities.
- Books, manuals, reprints that generally assist the PI in keeping up with his/her field of research.
Subscriptions will normally not be allowed as a direct charge to a federal research grant because their content is more general in nature and cannot be identified with a high degree of specificity to an individual research project.
Under unique circumstances, a PI may be able to provide a written justification supporting how the subscription meets the three tests of unlike circumstances described for the allowability of book charges above.
General Office Supplies back to top
General office supplies will normally not be allowed as a direct charge to a federal award. Because of their general nature they cannot be identified with a specific project with a high degree of accuracy. In instances, however, where the office supplies are not general and can be identified closely with a specific project, eg. special notebooks for laboratory use, supplies for poster or other presentations to disseminate scientific results, specialized supplies for recording or calibrating data, then such costs could be considered direct. Also, office supplies related to specific research projects of trainees on federal training grants could be considered training-related expenses and charged as direct costs.
Copier Charges, Copy Cards back to top
Copier charges and copier card costs will normally not be allowed as direct charges to federal research or training projects because of the difficulty in identifying the material copied and associating it specifically with an individual sponsored project.
Only copier usage that meets all three criteria for unlike circumstances may be charged directly to a sponsored project. Examples of allowable treatment of copier costs in meeting these criteria are as follows:
- Unlike circumstances exist, that is, this sponsored award is different from typical sponsored awards at Harvard University. Examples of awards with atypical need for copier costs include survey projects.
- Cost can be associated with the sponsored project with a high degree of accuracy. Ideally, the method to identify the copying cost with a specific sponsored project is to have that project's survey or other material copied separately at a copy center where the cost can be differentiated from general copying costs. Alternatively, the use of specific codes on a department copier is an acceptable methodology to identify unusual copying that meets all three criteria. General copying by the lab may not be charged directly to a federal award.
- The awarding agency has approved charging the cost as a direct cost in the awarded budget. Copying costs must be separately identified in the approved project budget.
Note: even when the cost to reprint or copy an article on a specific research technique will provide substantial help in furthering the experiments on a specific grant, it will be difficult to justify a copy charge on a grant unless all three criteria above are met.
Dues and Memberships back to top
Dues and memberships in professional organizations will normally not be allowed as a direct charge to a federal research grant because their purpose is more general in nature in furthering a PI's knowledge in his/her field and cannot be identified with a high degree of specificity to an individual research project.
Under unique circumstances, a PI may be able to provide a written justification supporting how a dues or membership cost meets the three tests of unlike circumstances.
Local Travel Costs (Meals, Parking) back to top
Please refer to the Harvard University Travel Policy for the complete text of the University's policy.
Domestic and foreign travel charged to a sponsored project should follow the guidelines set forth in the Harvard travel policy unless the funding agency imposes greater restrictions. In particular, note federal requirements to Fly America i.e. on an American carrier showing the American carrier's flight number. Also note in the HU travel policy the list of non-reimbursable expenses and expenses that may not be directly or indirectly charged to federal projects.
Note that Harvard Travel Policy may permit spending Harvard funds for these types of expenses but they may not be allowable on sponsored projects. In these cases, the cost should be charged to a faculty or departmental discretionary account.
At Harvard, "local environs" is defined as Harvard University and related areas normally within a 50 mile radius of Harvard Square.
A. Local Meals, Meals With No Associated Travel back to top of this section
The cost of purchased meals or food within the local environs will normally not be allowed as a direct charge to a federal research grant because the Harvard employee or trainee is not "traveling" and the cost is normally considered a personal expense. See below for special circumstances for federal training grants.
When a food or beverage cost meets the following three criteria, and the PI provides written justification of the business purpose of the expenditures and how they relate to the specific research project including purpose of the meeting, list of attendees, beginning and end times, a meal cost may be charged to a sponsored project:
- The cost must be allowable under both the provisions of A-21 AND under the terms of a specific award. The food and beverages must not be directly related to a social event.
- The cost must be allocable, that is, the project which pays the expense must benefit from it. More specifically, the food and beverage must be integral to a project-related event.
- The cost must be reasonable, that is the cost reflects what a "prudent person" would pay in a similar circumstance.
Examples of allowable food charges:
- Lunch and refreshments provided for periodic all-day meeting of collaborators on a program project (with formal agenda and participants from different locations).
- A post-doc being recruited to fill an open position on a research grant travels to Cambridge or Boston. Her meal may be charged to the grant since she is on travel status, but the PI's may not.
Examples of unallowable food charges:
- Lab personnel meet weekly to discuss progress on the grant.
- PI has lunch/dinner with a colleague and discusses research.
B. Parking Expenses back to top of this section
Similarly, parking expenses incurred in the local environs will normally not be allowed as a direct charge to a federal research grant because the Harvard employee or trainee is not traveling and there are many low-cost or no-cost alternatives. Again, when a charge meets the following three criteria, and the PI provides written justification, a parking cost may be charged to a sponsored project.
- The cost must be allowable under both the provisions of A-21 AND under the terms of a specific award.
- The cost must be allocable, that is, the project which pays the expense must benefit from it.
- The cost must be reasonable, that is the cost reflects what a "prudent person" would pay.
Generally, if mileage is reimbursable then so is parking incurred between trip start and end.
Examples of allowable parking charges:
- A PI drives within the local environs to meet with collaborators on a specific project.
- A researcher is working on a federally funded project that is spread among several labs in Cambridge and Boston.
- Subjects in a research study are reimbursed for parking expenses incurred when they visit the federally-funded study site.
Examples of unallowable parking charges:
- A consultant is hired to perform statistical analysis for an NIH-funded project. He comes to Harvard University to do this work. (Consultants should pay their own expenses.)
C. Spring Water back to top of this section
The University considers spring water to be an expense that does not inherently meet the three allowability criteria; for example, as allocable to an individual research project. Spring water should normally be charged to a faculty or departmental discretionary account or departmental budget account.
Under unlike purpose and circumstances, spring water may meet those criteria. One example of a circumstance under which spring water is allowable on a sponsored project is if the water is purchased for use by research subjects.
Telecommunications, Cellular Phones, Internet Access back to top
OMB Circular A-21, Section F6.b(3) notes that local telephone costs "shall normally be treated as F&A costs," i.e. not charged directly to federal projects. Section F 6.b.(1) notes that telephone toll charges "shall be treated as direct cost wherever identifiable to a particular cost objective. Direct charging of these costs may be accomplished through specific identification of individual costs to benefiting cost objectives." In other words, long distance charges may be charged directly to sponsored projects, ideally using specific identification of individual toll calls and projects from the itemized phone bill as documentation.
For the University direct cost charging purposes, we interpret A-21 to mean the following:
Normally treated as F&A cost:
The following types of costs will normally not be allowable as a direct cost on a sponsored project and instead must be charged to a departmental budget account, departmental discretionary or PI discretionary account.
- Local telephone service.
- Base fee for cell phone.
- Internet access or subscription fee [allowable if discrete access is required (as in an off-campus location) solely for the purpose of the project being charged (as in for research data transmission)].
May meet criteria to charge directly:
- Long distance telephone charges.
- Itemized cellular call charges.
For these items to be charged directly to a grant, the charge must also meet the three general federal allowability criteria listed above, namely:
- The cost must be allowable under both the provisions of A-21 AND under the terms of a specific award.
- The cost must be allocable, that is, the project which pays the expense must benefit from it. As noted in A-21, there must be an appropriate methodology to associate a specific cost to the benefiting project. The ideal methodology is specific identification of the person called and the benefit that call provided to the sponsored project.
- The cost must be reasonable, that is the cost reflects what a "prudent person" would pay. Using a cell phone when local telephone service is available may not meet this criterion.
Unlike Purpose and Circumstances
Under exceptional circumstances, local telephone expenses may be directly charged to a sponsored project. Exceptional circumstances apply when a project has a special or unique need for telephone communication. Phone usage must be significantly greater than the routine level required by academic or departmental usage. Procedures must be in place to ensure that the particular line is used exclusively for the project or activity to which it is being directly charged.
Examples of allowable local telephone charges:
- A dedicated line used to conduct a telephone survey.
- A phone line used exclusively to manage a multi-site research project.
Postage, Express Delivery back to top
- Postage
OMB Circular A-21, Section F6.b(3) notes that postage costs "shall normally be treated as F&A costs," i.e. not charged directly to federal projects. Postage costs must be charged to a departmental budget account, departmental discretionary or PI discretionary account.
- Express Delivery
Express delivery charges, e.g. Fed Ex, may be charged directly to a grant when the charge meets the three general federal allowability criteria listed above, namely:
- The cost must be allowable under both the provisions of A-21 AND under the terms of a specific award.
- The cost must be allocable, that is, the project which pays the expense must benefit from it. As noted in A-21, there must be an appropriate methodology to associate a specific cost to the benefiting project. The ideal methodology is specific identification of the recipient of the package or express delivery and the benefit of the package contents to the sponsored project.
- The cost must be reasonable, that is the cost reflects what a "prudent person" would pay.
Normally Charged Directly to Sponsored Projects
OMB Circular A-21, Section F 6.b.(1) identifies certain expenses that "shall be treated as direct cost wherever identifiable to a particular cost objective. Direct charging of these costs may be accomplished through specific identification of individual costs to benefiting cost objectives." In other words, as long as specific identification can be made linking an individual expense with a sponsored project, the Circular acknowledges that these costs are normally appropriate as direct charges. The complete list provided in Circular A-21 is as follows:
- Technical staff
- Laboratory supplies (e.g. chemicals)*
- Telephone toll charges*
- Animals
- Animal care costs
- Computer costs
- Travel costs*
- Specialized shop costs
*specific guidance provided above
Yet sponsored projects may incur other types of costs that do not fit in these categories. This section will provide a default treatment for other types of expenditures:
Other costs that may often be charged directly when the three allowability criteria are met:
- Laptop computers
- Desktop computers
- Installation of electrical outlets required for project equipment
Other costs that would not normally be allowable as a direct charge:
- Filing cabinets (normally facilities infrastructure)
- Desks
- General educational / training costs, e.g., software training that cannot be associated with a specific project
Special Considerations for Federal Training Grants back to top
While all the policies cited above apply to training grants, there are some special considerations for Trainee Related Expenses.
Trainee Related Expenses
Trainee Related Expenses (TRE's) are described in the NIH Grants Policy statement as "funds provided to defray such training costs as staff salaries, consultant costs, equipment, research supplies, staff travel and other expenses directly related to the training program." More specifically, the NIH Guide 26:16, expands the definition of TRE's as intended to "…enhance research training opportunities for individuals." There is probably not another direct cost category that carries a more liberal definition; nevertheless, certain categories must be handled carefully.
The following types of expenses are generally allowable/acceptable:
- Consultant costs including seminar speakers (and their travel, honorarium) and related seminar/symposium expenses.
- Announcements, posters, brochures (including shared recruitment) costs.
- The cost of videotaping seminars because the seminars are trainee-related and trainees would benefit as it provided unquestionable educational value.
- Staff salaries to support training grant administration are also acceptable with the 5% minimum described above.
- Trainee travel including transportation, lodging, meals.
- Book allowance, journal club, data club.
- PI travel and conference fee when attending a conference with trainees.
The following types of expenses are generally not allowable/acceptable:
- Food in general is not an allowable training expense.
- Meals without associated travel are very difficult to justify as a direct cost to a federal award of any type, particularly training grants.
- PI travel and conference fee when attending a conference without trainees.
