COST ACCOUNTING JUSTIFICATION

Purpose
General Information
Exhibit and Instructions
Form Requirements
Number of Copies and Ultimate Distribution
Where To Send Completed Forms
Contact Information
Cross References

Use of Google Chrome Required

NOTE: Google Chrome must be used to access the GURU website and for completing and/or downloading fill-and-print forms. Firefox, Internet Explorer, and/or Microsoft Edge browsers do not support all features required for PDF fill-and-print form functionality. substitutes for an approved University official form (created using a different browser or scanned copies) will be returned along with the request to use the Chrome version of the form.

Purpose:

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

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:

Administrative and clerical salaries (support personnel): This includes departmental staff who provide support for all departmental operations, including research or contract administration and includes administrative assistants, departmental IT staff and others who provide general support for all operations.

Non-Personnel Costs

General purpose equipment and supplies: This category includes paper, toner, office supplies, as well as printers, laptops, computers and software and related peripherals.
Other costs: This category includes, but is not limited to, photocopying, mailing services, telecommunication costs, memberships and group meals. This list is not exhaustive and there may be other non-personnel costs not listed here which would be considered administrative, and therefore would require the exception.

Cost Accounting Justification Non-Personnel Costs Checklist - This form is optional. It is intended to assist Principal Investigators, Research Administrators and Financial Officers to evaluate the justification of charging costs, which are normally charged as Facilities and Administration expenses such as general purpose items, services, computers or supplies, directly to a sponsored program. If used, please attach to a Non-Personnel Cost Accounting Justification form.

More detail on these expenses are 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:

Allowability: A specific justification of how this cost will directly support the research being conducted - the project specific need for this cost as a direct charge to the project.

Allocability: A specific allocation of this cost to the project. The detailed criteria to meet the allocability standard are available in the Uniform Guidance - §200.405 Allocable costs. A cost is allocable to a sponsored agreement if:
- is incurred solely to advance the work funded under the sponsored project;
- benefits both the sponsored project and other work of Penn State in proportions that can be clearly documented through reasonable methods

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.

NOTE:
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:

Principal Investigator (PI) - signature indicates that the PI asserts that this is a valid expense to charge directly to the sponsored award, based on the PI's assessment of the reasonableness, allowability, and allocability of the cost to the project.
Department Head or Institute Director (Admin. and Clerical Costs Justification only) - signature indicates that the Department Head or Institute Director approves of the cost of the administrative or clerical support position and will cover costs if later disallowed.

Research Administrator or Financial Officer - signature indicates agreement that costs are reasonable, allocable, and allowable as a direct charge to the sponsored award, given the justification provided by the PI.

Associate Dean/VP for Research/Campus DAA (Admin. and Clerical Costs Justification Only) - signature indicates final approval that cost may be treated as a direct charge to the sponsored award given the justification provided by the PI.

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

Exhibit and Instructions:

These forms have the digital ID (signature) process enabled. The PDF version has instructions provided for the type and/or format of information to be included within the fill-and-print form fields. Hovering the computer mouse over any form field within the PDf will display these instructions. See Converting Web-based Documents to PDF Documents for details. See Applying Digital IDs When Document Contains Multiple Signatures for instructions on adding signatures.

To view a printed version of these instructions, 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 Associate Vice President for Budget and Finance). See Policy FN17 Required Use of Approved University Forms Appearing in the General University Reference Utility (GURU) for full details.

Accessing GURU Forms:

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 adobe.psu.edu. If Adobe Acrobat Pro better suits your needs, contact your IT support staff person for purchasing and installation assistance.

Web-based Documents:

Clicking the form download icon on any of the form instruction pages on GURU will open a web-based version of the form. While it appears to have fill-and-print fields available, not all functionality may be available for use (i.e., digital ID fields). It will be necessary to convert these web-based documents to PDF documents (see Converting Web-based Documents to PDF document section below).

Converting Web-based Documents to PDF Documents:

There are two (2) options available to download the form:

Option 1 - To create a PDF for this document (and this document only):

Click the form download icon on the form instruction page to open the web-based version of the form
click the download icon located in the upper right-hand corner of the web-document
Select a location to save the document where you will be able to locate and open the new document
Click "Save"
Open the document from the saved location

Option 2 - Change system settings to always open documents with Adobe:

Click the form download icon on the form instruction page to open the web-based version of the form
Click the download icon located in the upper right-hand corner of the web-document
Select a location to save the document where you will be able to locate and open the new document
Click "Save"
The file will appear in the bottom left-hand corner of your browser window. Click the small up arrow to the right of the file name
Click the "Always open with system viewer" option
The form now opens as a PDF and can be completed
All PDF files will now open in a separate window with Adobe

Exceptions:

Combining PDF Documents:

There may be times when it is necessary to combine multiple PDF documents into a single document for submission. In those instances, complete the following steps:

Click on the appropriate form in GURU
Complete the fill-and-print boxes on the web-based form, but do not apply any digital IDs
click the printer icon located in the upper right-hand corner of the screen
Change Destination to Microsoft Print to PDF using the drop-down arrow
Click Print at the bottom of that panel
Enter a file name in the box at the bottom of the pop-up window and be sure to select a location where you will be able to relocate the document
Click Save

Repeat this process for each document that will be combined (each file name must be different from the previous).

Open one of the completed PDF documents and on the far right select combine fines
Click Add Files and Select the files to be combined
Click Combine
Rename this new combined document and save
Open this new combined document and apply any and all digital IDs (in appropriate)

Applying Electronic Signatures on PDFS (general instructions):

NOTE: Once a digital ID has been applied to a document, it is considered an "approved" document and it is not possible to make any revisions to the form. DO NOT apply any digital IDs until the document has been completed and is ready to be approved.

Complete all fill-and-print form fields before completing the signature process:

Once the form is completed, click in the signature form field and either:

select your digital ID and click continue, or
create your digital ID, select your digital ID, and click continue

Review the information in the appearance box and click sign
You will be required to save a copy of the document (the digital signature is not applied until the form is saved)
- A pop-up window opens with the file name in the File Name field. Add a dash and account number or OSP number to the end of the file name (i.e. cost-accounting-justification-administrative-form-123456)
- Select a location where you will be able to retrieve the document
- Click Save
Close the form version appearing on your screen
Open the version created in the previous step
Verify the digital ID appears on the document
Close the document

Creating a Proxy Digital ID:

If authority has been delegated to act as a proxy for signing forms, it will be necessary to create a "proxy digital ID." The individual authorization another to act as their proxy must provide written documentation to the individual being proxied. The individual receiving the proxied authority must retain this written documentation for the duration of the proxy.

Complete the following steps to create a proxy digital ID:

Click in the signature form field
Click "Configure New Digital ID" in the "Sign with a Digital ID" box
Select "Create a New Digital ID" and click Continue
Select "Save to File" and click Continue
Enter "[Your name] proxy for [enter name]" in the Name field and complete the other fields (as appropriate) but the email address is required (this would be your email address) and click Continue
Select a location to save the new Digital ID (or leave as assigned), apply a password that you will use for signing, and click Save

Applying Electronic Signature When the Document Contains Multiple Signatures

Cost Accounting Justification for Administrative/Clerical Costs:

The Cost Accounting Justification for Administrative/Clerical Costs form requires multiple signatures for approval. Please complete the following process for obtaining those signatures:

The Principal Investigator completes the "To Be Completed by the Principal Investigator" section, applies their digital ID, and saves the form using the naming convention defined above
The Principal Investigator sends an email, with the above referenced document as an attachment, to the Department Head or Institute Director
The Department Head or Institute Director opens the attachment and completes the "To Be Completed by the Dept. or Research Admin." section and applies their digital ID (if approving) as defined in Steps 1, 2, and 3 above and saves the document again (do not change the file name)
The Department Head or Institute Director sends an email, with the above referenced document as an attachment, to the Research Administrator or Business Area Financial Officer for review
The Research Administrator or Business Area Financial Officer open the attachment and, if approving, applies their digital Id, enters relevant comments, and saves the document (do not change the file name)
The Research Administrator or Business Area Financial Officer send an email, with the above referenced document as an attachment, to the Associate Dean, Vice President for Research, or Campus DAA (as appropriate) for review
The Associate Dean, Vice President for Research, or Campus DAA opens the attachment, checks approve or deny, and applies their digital ID (if approving) and saves the document again (do not change the file name)
The Associate Dean, Vice President for Research, or Campus DAA sends an email, with the document as an attachment, to the Principal Investigator to be retained by the area and included in the contract file.

Cost Accounting Justification for Non-Personnel Costs:

The Cost Accounting Justification for Non-Personnel Costs form requires multiple signatures for approval. Please complete the following process for obtaining those signatures:

The Principal Investigator completes the top portion of the form, applies their digital ID, and saves the form using the naming convention defined above
The Principal Investigator send an email, with the above referenced document as an attachment, to the Research Administrator or Business Area Financial Officer
The Research Administrator or Business Area Financial Officer opens the attachment, checks approve or deny, and applies their digital ID and saves the document again (do not change the file name)
The Research Administrator or Business Area Financial Officer send an email, with the above referenced document as an attachment, to:
- The optional approvers, or
- The Principal Investigator to be retained by the area and included in the contract file

Cost Accounting Justification for Non-Personnel Costs Checklist:

The Cost Accounting Justification for Non-Personnel Costs Checklist requires the Principal Investigator's signature and, if used, attached as supporting documentation to the Cost Accounting Justification for Non-Personnel Costs form.

Clearing Fill-and-Print Form Fields:

This form has the "Clear Form" Bookmarks enabled. To clear ALL form field entries:

If left-hand column is not displayed when the document is opened, click the small arrow located at about the mid-point of the left-hand side of the screen to reveal the column
Click "Bookmarks" (looks like a ribbon)
Click "Clear Form"

If you encounter any difficulties, contact the GURU support staff by submitting a Technical Support Form request.

Number of Copies and Ultimate Distribution:

Table of distribution and retention of the Cost Accounting Justification forms:
Document:	Ultimate Distribution:	Retention Periods:	Disposition Method:
Original (Administrative/Clerical Costs and/or Non-Personnel Costs forms)	Project/Contract File	End of fiscal year after close of project/contract +7 years	Paper documents = Secure Bin disposal or shred Electronic document and data =delete and empty computer recycle bin
Transitory Copies*	Copies created during the electronic signature process	Upon verification of document added to project/contract file - End of fiscal year +1 year	Paper documents = Secure Bin disposal or shred Electronic document and data =delete and empty computer recycle bin

*Transitory/Disposable Records - University Records that have temporary value and, as a result, may be destroyed after they are no longer needed. In no event shall be retained longer than the official copy of the University Records as delineated on the Records Retention Schedule.