June 01, 2009

Direct Charging Administrative Support Costs on ARRA Projects

UCOP has issued C&G Guidance Memo 09-02 indicating that the OMB has told the Council on Governmental Relations (COGR) that administrative support charges on ARRA proposal budgets will not be allowed strictly on the basis that the project is ARRA funded. UCOP is in the process of updating our C&G Guidance Memo web site to reflect this outcome.

COGR’s PRELIMINARY understanding is that for NIH applications that included a direct charge for ARRA Specialist salaries, each IC will have discretion in determining if the amount awarded needs to be reduced. For example, in the case of NIH Challenge Grants that are limited to total costs of $500,000 per year, the presumption is that if ARRA Specialist salary costs had not been requested, then other costs could have been justified. Therefore, awarding the full $500,000 would be appropriate, with re-budgeting of the ARRA Specialist salary costs to other allowable direct costs. Submission of a revised budget would not be necessary.

April 10 Research Advocate article: Direct Charging Departmental Administrative Support Costs to ARRA Projects