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INDIRECT COST PROPOSAL COMMONALITIES

Nine NPCs that administer federal funds were contacted regarding their Indirect Cost Proposals (ICP). The purpose was to determine what expenditures are typically included - or may be included - as indirect costs in the ICP. Compiling and sharing this information accomplishes two objectives. First, including the same types of costs as indirect encourages inclusion of all allowable costs. Second, some homogeneity can be achieved among the costs allocated as indirect by NPCs.

Three types of costs are incurred in administering federal awards:

  1. those that are always direct, i.e., those identifiable to specific award(s), charged or directly supported by the award(s);
  2. those that are always indirect, i.e., costs directly related to management with no direct benefit to a research grant; and
  3. those that could go into either category depending on the circumstances.

In regard to Items 2 and 3, NPC’s surveyed typically used most or all of the following accounts in reporting their management (indirect) expenses:

  • Salaries, Wages

  • Payroll tax expense

  • Employee benefits

  • Advertising (for employee recruitment)

  • Bank charges

  • Computer software and supplies

  • Computer maintenance and support

  • Conference registration, education, meetings and training

  • Depreciation

  • Subscriptions, Dues, Books, Journals

  • Employee recruitment and relocation

  • Equipment rental

  • Small equipment

  • Insurance

  • IRB fees

  • Joint Personnel Act (JPA) costs

  • Loss on disposal of equipment

  • Office supplies

  • Outside services

  • Postage and delivery

  • Printing and publication

  • Professional fees

  • Repairs and maintenance

  • Support services (support to VA)

  • Taxes, permits, fees, business licenses

  • Telephone

  • Travel

The “gray zone” comprises various expenses supporting the investigators and their research that may or may not be included as indirect costs, depending on the circumstances. If these costs are to be classified as indirect, it is essential that they not be allocated to award-specific accounts. For example, support may derive from residual funds from an industry sponsored grant, from seed funding provided by the NPC for non-project specific costs, or from other administrative support provided by the NPC. The following categories may have costs allocated as indirect in the proper circumstances:

  • Books, journals, reference materials
  • Computer software (general, not grant specific) and supplies
  • Conference registration fees and related travel
  • Dues and subscriptions
  • Employee recruitment and relocation
  • IRB fees
  • Meetings and training
  • Overhead charges on JPAs
  • Office supplies for the PI
  • Postage and shipping
  • Printing and publication
  • Repairs and maintenance

Other costs that might be considered indirect when the expenditure will benefit multiple projects include the following:

  • CORE facilities and general research support - grant writers, IT support, pharmacy support, administrative staff, lab improvements and maintenance
  • Lab supplies - low dollar amounts of general use supplies used by multiple projects
  • Leased research equipment used for multiple projects
  • Small equipment and computers used for multiple projects

Also, “Bid & Proposal” is a legitimate category of indirect cost used by some of the larger nonprofits which is understood by and acceptable to the DHHS Division of Cost Allocation. This would include expenditures for pilot or preliminary studies leading to grant submissions or proposals.

Many subjective and interpretive elements come into play in the development of an indirect cost rate. NPCs embarking on this process should obtain the services of expert consultants or colleagues with considerable experience.

 

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last updated: 01/04/10

 

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