U.S. Government Policies

Grants and Cooperative Agreements

The OMB (Office of Management and Budget) Circulars are the documents that govern all federal grants.  The following are the circulars that are pertinent to research conducted at educational institutions: 

Research.gov:  The Research.gov Policy Library is the U.S. Government's electronic portal for accessing Federal policies, guidelines and procedures. 

A-21: Cost Principles for Educational Institutions;
See below for the text of Exhibit C, Examples of "major project" where direct charging of administrative or clerical staff salaries may be appropriate.

A-110: Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations;

A-133: Audits of States, Local Governments, and Non-Profit Organizations;

Code of Federal Regulations  is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government.

The Federal Demonstration Partnership (FDP) is a cooperative initiative among 10 federal agencies and 92 institutional (university) recipients of federal funds; its purpose is to reduce the administrative burdens associated with research grants and contracts.  

Contracts

The FAR (Federal Acquisition Regulations) governs all federal contracts.  The agency specific contract regulations can also be accessed from the FAR.

IPAs

An IPA (Intergovernmental Personnel Act) Agreement is one in which Georgetown faculty members may take a one year leave of absence to work at a federal agency.  The concept of the program is one of mutual benefit so while the GU faculty member works full time at the government agency, he or she remains a University employee with all customary benefits.  When an IPA Agreement is negotiated, the budget lines include salary and fringe benefits only.  Additional details about this program can be found at the Office of Personnel Management site.

Exhibit C -- Examples of "major project" where direct charging of administrative or clerical staff salaries may be appropriate.

  • Large, complex programs such as General Clinical Research Centers, Primate Centers, Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
  •  Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies). 
  •  Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
  • Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
  • Projects that are geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research fields sites that are remote from campus.
  • Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications. 

These examples are not exhaustive nor are they intended to imply that direct charging of administrative or clerical salaries would always be appropriate for the situations illustrated in the examples. For instance, the examples would be appropriate when the costs of such activities are incurred in unlike circumstances, i.e., the actual activities charged direct are not the same as the actual activities normally included in the institution's facilities and administrative (F&A) cost pools or, if the same, the indirect activity costs are immaterial in amount. It would be inappropriate to charge the cost of such activities directly to specific sponsored agreements if, in similar circumstances, the costs of performing the same type of activity for other sponsored agreements were included as allocable costs in the institution's F&A cost pools. Application of negotiated predetermined F&A cost rates may also be inappropriate if such activity costs charged directly were not provided for in the allocation base that was used to determine the predetermined F&A cost rates.