1405 Charging of Facilities and Administrative ("F&A") Type Expenses to Non-Federal Sponsored Projects

Policy Sections

1405.1 Types of Expenses

1405.2 Authorization of Expenses

1405.3 Documentation of Expenses

1405.4 Unallowable Expenditures

This policy applies to sponsored projects funded directly by non-federal sponsors or a subaward where the prime sponsor is a non-federal organization.

This policy establishes the requirements for the charging and approval of expenditures on awards from non-federal sponsors which do not reimburse the University at the federally approved Facilities and Administrative (“F&A”) cost rate. For more information on F&A, see Policy 6002 Application of Facilities and Administrative (“F&A”) Rates and Costs Recovery.

Many non-federal sponsors do not fully reimburse the University for its Facilities and Administrative (“F&A”) costs (commonly referred to as Indirect Costs) on sponsored awards.  In recognition of this practice, Yale expects these non-federal sponsored projects to directly pay for costs which are normally F&A costs if:

• the terms and conditions do not specifically prohibit such costs; and
• a benefit exists to the sponsored project.

Direct Costs

Costs that can be specifically identified with a particular sponsored project, an instructional activity, or any other institutional activity relatively easily and with a high degree of accuracy. Typical costs charged directly to a non-federal sponsored project may include but are not limited to: the compensation of employees working on the project; employee benefits; the cost of supplies and equipment used solely in the performance of the project; travel; subaward costs; service center charges; human subject fees, and long-distance telephone costs.

Indirect Costs

Costs that cannot be specifically identified with a particular sponsored project, an instructional activity, or any other institutional activity relatively easily and with a high degree of accuracy. Typical costs may include but are not limited to: compensation of employees working in the Post Award Financial Operations, Office of Sponsored Programs, Accounts Payable, Sourcing, and Human Resource departments; building utility costs; and building and equipment depreciation.

In order for the University to recover costs that are typically included in the F&A rate calculation from non-federal sponsors that do not reimburse the University at the full approved rate, departments are encouraged to include the costs identified below in proposals to these non-federal sponsors for grant and contract awards.  

The Direct Cost items that may be requested for reimbursement include but are not limited to:

a.   School/Department Administrative Costs:

• Administrative and clerical salaries;
• Communication Expenses; and
• Office supplies

Note: If a specific School’s/Department’s administrative costs for a project cannot be precisely quantified and charged directly, the School/Department may be able to negotiate a reasonable reimbursement of the project’s fair share of these costs.  To determine a fair share, any or all of the anticipated School/Department Administrative costs should be added together and the proposal budget should indicate a total for “administrative costs”. Salaries representing 5% effort or greater cannot be included in the category of “administrative costs”, must be budgeted separately in the proposal and charged directly to the sponsored project as salary.  An effort report will be generated supporting this effort and salary to the sponsored project.  

b.   Protocol Specific and Research Infrastructure Costs:

• Protocol design fees for clinical trials requested by sponsor;
• Pharmacy fees for clinical trials;
• Institutional Review Board (“IRB”) and Institutional Animal Care and Use Committee (“IACUC”) review fees; and
• Environmental Health and Radiation Safety fees for waste disposal and radiation safety tests.

c.   Subaward Costs:

The full cost of the subaward will be charged the applicable F&A rate of the non-federal sponsor, not just the first $50,000 as with federal subawards.

d.   Other

• Dues and memberships;
• Books and periodicals;
• Space costs; and 
• Space directly associated with research can be charged based on a gross square footage assignment obtained from the Facilities Office. This assigned space would then be assessed the Facilities rates for utilities and building services.

Note:  Expenditures on a non-federal sponsored project must not be prohibited by the sponsor in its terms and conditions or by University policy.

The principal investigator (“PI”) is responsible for the management and administration of his/her award within the constraints imposed by the sponsor and in accordance with University policy. The PI must authorize all expenditures of project funds unless otherwise delegated in writing, to a responsible designee.

Documentation of the appropriateness of these expenses in relation to the project must be maintained by the department.  Appropriateness of the cost must also be considered prior to processing the expenditure.  The factors for assessing appropriateness are:

• Allowability. The expense must be permitted by the sponsor and be in accordance with University policy. 
• Allocability. The cost can easily be identified with the project and be assigned to the project in accordance with benefits received.
• Reasonable and Necessary. The cost must be necessary for the performance of the award and reflect the action that a prudent person would have taken.
• Costs must conform to limits or exclusions set forth in the sponsored agreement or University policy.

Certain costs may not be charged to sponsored projects either as Direct Costs or as part of the F&A rate. See Procedure 1305 PR.04 for a description of common unallowable costs (non-reimbursable by the Federal government) and how to treat them.

Principal Investigator (“PI”)

• Identify those types of expenses needed to conduct the project as proposed and awarded.

Departmental Business Office

• Assists the PI in reviewing the terms and conditions of the sponsored agreement and University policy to determine if the expense is specifically prohibited from being charged to the award.

Office of Sponsored Projects and Sponsored Projects Financial Administration (“SPFA”)

•  Provides guidance to Business Offices and PIs on the appropriateness of an expense on the sponsored project.