OMB Circular A-21 General Overview – F&A OSP Brown Bag Norm Hebert, Director December 8, 2005

General Overview of A-21 and F&A (indirect costs): Locating a copy of OMB Circular A-21 Applicability and Purpose of A-21 Acceptance of rates by Federal Agencies Standards for Allowable Costs Allowable Cost types (direct and indirect) F&A simplified

OMB Circular A-21 2 CFR Part 220 Go to: click on “Educational and Non-Profit Institutions” - then, click on OMB Circular A-21

OMB Circular A-21 Cost Principles for Educational Institutions Applicability: All Federal agencies that sponsor research and development, training, and other work at educational institutions shall apply the provisions of this Circular in determining the costs incurred for such work. The principles shall also be used as a guide in determining the price of fixed price or lump sum agreements.

OMB Circular A-21 Cost Principles for Educational Institutions Purpose: Establishes principles for determining costs applicable to agreements with educational institutions…designed to provide that the Federal Government bear its fair share of total costs…agencies are not expected to place additional restrictions on individual items of cost.

OMB Circular A-21 Cost Principles for Educational Institutions Acceptance of (F&A) rates: Negotiated rates shall be accepted by all Federal agencies. Only under special circumstances, when required by law or regulation, may an agency use a rate different from the negotiated rate for a class of sponsored agreements or a single sponsored agreement.

Standards for allowability of costs: Cost must be Reasonable Cost must be Allocable Cost must be given Consistent treatment within institution through generally accepted accounting principles (GAAP) And conform to limitations or exclusions in these principles

Reasonable Costs Prudent person rule – action that a prudent person would take under the circumstances: Type of cost necessary for operation of institution or performance of the sponsored agreement Consistent with laws and regulations and the agreement terms and conditions Individuals involved acted with due prudence in the circumstances Actions are consistent with policies and procedures of the institution

Allocable Costs Cost is assignable in accordance with relative benefits received – allocable to sponsored agreement if cost: Is incurred solely for work under the sponsored agreement Benefits work in proportions that can be approximated through reasonable methods Necessary for operation of the institution and consistent with these principles

Consistency Consistent treatment within Institution through generally accepted accounting principles (GAAP) Conforms to limitations or exclusions in these principles

Allowable Cost Types Direct costs: –Can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity –Can be directly assigned to such activities relatively easily with a high degree of accuracy

Allowable Cost Types F&A costs: –Incurred for common or joint objectives –Cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity

F & A Costs Facilities Depreciation and use allowances for buildings and equipment Interest on debt for certain buildings Equipment and capital improvements Operation and maintenance expenses Libraries

F & A Costs Administration General administration and general expenses Departmental administration Sponsored projects administration Student administration and services

Aggregated Costs Expressed as a Simple Fraction: Percent = F&A Rate F&A Costs = XX% Direct Costs

Example: $38.5 Million F&A Costs = 55% $70 Million Direct Costs

Impact of Direct Cost Cost-Sharing Add 10% Direct Cost Cost-Share (provided by institution) $38.5 Million F&A = 50% $77 Million Direct Costs

Question: Brown’s Total Direct Cost FY ’05: $116 Million (55%= $63.8 Million) How much F&A did we recover? a)> $60 Million b)$45 Million - $59.9 Million c)$30 Million - $44.9 Million d) < $30 Million

Question (Hint) MTDC = $88 Million (55%=$48.4 Million) a) > $45 Million b)$38 Million - $44.9 Million c)$30 Million - $37.5 Million d) < $30 Million