Systems and Procedures
A Division of The Corporate Controller's Office


Table of Contents:


The Cost Accounting Justification Forms are to be used to treat the costs normally considered indirect as a direct cost for a sponsored agreement.

General Information:

The Uniform Guidance 2 CFR 200.56 , disallows the direct charging of facilities and administrative type costs on federal sponsored agreements. However, there are certain unique exceptions to this rule allowing for the direct charging of these types of costs in the event the University can justify the charges. Determining if a cost should be included as a direct cost should normally be done at the proposal stage . There are certain departmental costs which are included as Facilities and Administrative (F&A), and therefore, should not be included as a direct cost. Principal Investigators (PI) should work closely with the Research Administrator to ensure that costs normally considered F&A are not included as direct costs in a proposal, unless there is a compelling reason to do so. See Policy RA21 - Development of Proposal Budget for additional guidance.

Facilities and administrative type costs are incorporated into the F&A rate charged as an indirect cost to the grant. The types of costs which cannot normally be direct charged are:

More detail on these expenses is included in the Cost Accounting Standards FAQ . This document should be reviewed before completing this form.

These costs may be permissible as direct charges. Adequate justification regarding the allowability and allocability of the expense must be documented, through the justification form. The justification must provide detail regarding:

At the discretion of the Administrative Area, the justification can be prepared either during proposal preparation or when allocating the cost to a sponsored program. The preferred method is during proposal preparation. The cost must be approved before being charged to the sponsored program. Regardless of the timing, the proposal should provide detailed justification for including these costs as direct charges. Generally, if the cost is not included in the proposal, it will not be permitted as a direct cost at the time of purchase.


General purpose equipment is not allowable except with the prior written approval of the Federal awarding agency or pass-through entity (2 CFR 200.429(b)(1)).

Administrative or clerical salaries are not allowable unless they are explicitly included in the budget or have the prior written approval of the Federal awarding agency (2 CFR 200.413(c)).

The appropriate form - one for Administrative/Clerical costs and the other for Non-Personnel costs - must be completed as indicated, and signed by the Principal Investigator, and approved by those listed. Approval indicates the following:

The forms will become a part of the official grant / contract file.

Exhibit and Instructions:

To view document exhibits, click on links below:

Cost Accounting Justification - Administrative/Clerical Costs Exhibit

Cost Accounting Justification - Non-Personnel Costs Exhibit

Cost Accounting Justification - Non-Personnel Costs Checklist Exhibit (optional)

Form Requirements:

No form may be used that substitutes for an approved official University form without prior review and approval by the steward of the form/central office, as facilitated by the Office of Systems and Procedures (designated representative of the Corporate Controller). See Policy FN17 - Required Use of Approved University Forms Appearing in the General University Reference Utility (GURU) for full details.

GURU PDF forms are designed for use with Adobe Acrobat Reader or Adobe Acrobat Pro. Each browser (Chrome, Firefox, Internet Explorer, etc) has a built-in PDF viewer making it the default PDF viewer without asking users. These built-in viewers do not necessarily support all features required for PDF Forms. Similarly, many calculations are not supported by other stand-alone PDF readers (for example, Nuance). If you experience problems downloading or opening documents, right click on the link on the Forms Locator Screen, select 'Save Link As' (or similar language) and save the file. The document can then be opened in either Adobe Acrobat Reader or Adobe Acrobat Pro from the saved location.

The latest version of Adobe Acrobat Reader is available for free. Contact your IT support staff person for downloading assistance, if/as needed. An Adobe Creative Cloud (CC) account is also available to all Penn State students, faculty, and staff members, at no cost. Sign up for an Adobe Creative Cloud account at If Adobe Acrobat Pro better suits your needs, contact your IT support staff person for purchasing and installation assistance.

If you encounter any difficulties, contact the GURU support staff by submitting a Technical Support Form request or by calling the tech support line at 814-863-8592.

Number of Copies and Ultimate Distribution:

Table of distribution and retention of the Cost Accounting Justification forms:
Ultimate Distribution: Retention Periods:
Original White Project File 3 years AFTER the end date of the agreement

Where to Send Completed Forms:

Once all signatures are received, the form is to be retained by the area and included in the contract file.

Contact Information:

For questions, additional details, or to request changes to this form, contact Research Administration.

Cross References: