Charging Costs Directly or Indirectly to Sponsored Projects

Directive Statement

Cost Accounting Standard (CAS) 9905.502 states “All costs incurred for the same purpose, in like circumstances, are either direct costs only (can be charged to a grant) or indirect costs only (must be paid with unrestricted funds) with respect to final cost objectives.” Uniform Guidance 2 CFR 200 then goes on to list specific costs that the federal government considers to be normally charged indirectly, “Items such as salaries of administrative and clerical staff, office supplies, postage, local telephone costs and memberships”.

The Uniform Guidance does allow for exemptions where cost items normally treated as indirect (F&A) costs may be charged directly if certain conditions are met.

Principal Investigators (PIs) who believe circumstances of their federally funded project warrant a CAS exemption that would allow direct charging costs that are normally treated as indirect (F&A) must submit a Cost Accounting Standard (CAS) exemption request through UFIRST.

Reason for Directive

To comply with the Federal government’s Uniform Guidance, codified at 2 CFR 200, which incorporates the Cost Accounting Standards (CAS) 48 CFR 9905.501, 9905.502, 9905.505, 9905.506, the University of Florida has determined the following costs shall normally be treated as indirect (F&A) or unallowable as a direct charge to a federally sponsored award unless a CAS Exemption is approved.

Who must comply?

All University Departments.

Costs and myUFL Account Codes Normally Treated as Indirect (F&A) costs and Not Charged Directly to Federally Funded Sponsored Agreements

Salary and Wage Expenditures

Operating Expenditures

Group 1 Cost Items:
For a direct charge to an item in Group 1 that is normally indirect a CAS Exemption is required.

Group 2 Cost Items:
For a Group 2 cost item to be direct charged a CAS Exemption is required and will normally only be approved where the costs have been specifically budgeted for and/or justified as essential or necessary to the performance of the project or activity being funded, otherwise sponsor approval is required.

Group 3 – Normally Unallowable Costs:
For a Group 3 normally unallowable cost item to be direct charged, a CAS Exemption is required and will only be approved where the costs have been specifically budgeted for and/or justified as essential or necessary to the performance of the project or activity being funded, otherwise sponsor approval is required.

Most Common Costs and myUFL Account Codes that are Charged Directly to Federally Funded Sponsored Agreements

This list of cost items is not intended to be all inclusive. Other costs will be allowed as a direct charge so long as the item and amount are considered necessary, reasonable, allocable, and allowable under Uniform Guidance (UG) 2 CFR 200.

Salary and Wage Expenditures

 Operating Expenditures

Non-Federal Sponsored Agreements

All costs that are reasonable, allocable, and necessary for the performance of the project or activity being supported by the non-federal award may be direct charged, subject to any special terms and conditions.

Resources

2 CFR 200 Quick Reference Guide

Uniform Guidance 2 CFR 200

48 CFR 9905 – Cost Accounting Standards (CAS) for Education Institutions

Toolkits

UF HR Toolkit – CAS Exemption Process

Training

RSH260: Cost Principles

RSH206: Cost Principles Advanced Topics

RSH282: UFIRST Awards

RSH212: Post Award Overview

Contacts

Cost Analysis: (352) 392-5778

Contracts and Grants Accounting: (352) 392-1235