COST ACCOUNTING JUSTIFICATION
Table of Contents:
- General Information
- Exhibit and Instructions
- Form Requirements
- Number of Copies and Ultimate Distribution
- Where To Send Completed Forms
- Contact Information
- Cross References
The Cost Accounting Justification Forms are to be used to treat the costs normally considered indirect as a direct cost for a sponsored agreement.
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:
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 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:
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.
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.
To view document exhibits, click on links below:
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. Past experience indicates that these built-in viewers do not support all the 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 located 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 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. 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.
|Ultimate Distribution:||Retention Periods:|
|Original||White||Project File||3 years AFTER the end date of the agreement|
Once all signatures are received, the form is to be retained by the area and included in the contract file.
For questions, additional details, or to request changes to this form, contact Research Administration.
- Policy AD35 - University Archives and Records Management
- Policy RA21 - Development of Proposal Budget
- Policy FN17 - Required Use of Approved University Forms Appearing in the General University Reference Utility
- Uniform Guidance 2 CFR 200.56
- Uniform Guidance - §200.405 Allocable costs