Compliance with Federal Cost Principles

Uniform Guidance and associated Cost Accounting Standards (CAS) requires that Universities comply with a certain regulations, including four Cost Accounting Standards. In order for an expense to be considered appropriate as a direct cost the charge must be:

  • Allowable – The cost must be allowable per the terms and conditions of the sponsored award, under applicable sponsor regulations, Uniform Guidance, 200.403, and University policies
  • Reasonable – The cost may be considered reasonable if the nature of the goods or services acquired, and the amount involved reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. Key factors in determining reasonableness are defined in Uniform Guidance, 200.404
  • Allocable – The cost must benefit the project and be directly attributable to the project or activity being performed. The cost can only be assigned and allocated to the project(s) based on that portion of the expense that represents the direct benefit to the project. In order to ensure allocable standards are met refer to Uniform Guidance, 200.405
  • Consistently treated – Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or F&A costs in order to avoid possible double charging of Federal awards. Refer to Uniform Guidance, 200.412, 200.413 and 200.414 for additional information

Reason(s) for the Policy

To formalize guidance to Principal Investigators and others responsible for the administration of Sponsored Projects on the University's requirements for complying with Federal Cost Accounting Standards. Primary Guidance to Which This Policy Responds Cost Principles, as set forth in 2 CFR Chapter I and Chapter II Part 200 Uniform Administrative Requirements, Cost Principles.

Responsible University Office & Officer

Office of the Controller

Fabrizio Carucci, Associate Vice President, Research Policy and Indirect Cost

Who is Governed by This Policy

Faculty and staff responsible for the administration of sponsored projects Controller's Office staff engaged in sponsored projects oversight

Who Should Know This Policy

  • All persons governed by this Policy {see above}
  • Departmental Administrators and other departmental staff
  • Deans and Departmental Chairs
  • Office of Research Administration staff
  • Office of the Controller staff