OMB Uniform Guidance and Cost Accounting Standards with Major Project Examples
Find out about the OMB Uniform Guidance and Cost Accounting Standards, major components of fiscal compliance. See examples of major projects — projects that require an extensive amount of administrative or clerical support.
UCSD Compliance
UCSD must comply with the UG requirements to ensure the recovery of direct and indirect (F&A) costs. As a required element of UG, the University must disclose its cost accounting practices in writing to the federal government. UCSD satisfied this requirement with the disclosure statement (DS-2) submitted to the federal government in 1996.
OMB Uniform Guidance
Anyone authorizing the expenditure of federal funds must have a working understanding of the underlying cost principles as set forth in OMB Uniform Guidance. These principles govern costs that may be charged either directly or indirectly to the government by educational institutions. UCSD generally applies these same cost principles to non-federal funding as well, although in some cases non-federal sponsors define costs differently than federal sponsors.
About major projects
Definition of major project
A major project is a sponsored project that requires an extensive amount of administrative or clerical support that goes beyond the routine level of such services provided by academic departments. In major projects, administrative or clerical salaries may sometimes be considered direct instead of indirect (F&A) costs.
Charging administrative and clerical costs as direct
If you are considering charging administrative or clerical expenses against federally sponsored projects that fall within the major project classification, see Charging Administrative and Clerical Costs as Direct.
OMB Uniform Guidance
OMB Uniform Guidance provides the following examples of major projects (UCSD comments are in bold):
- 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 many institutions
- Projects that 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)
- Examples: Projects involving substantial patient care or patient care data, including patient recruitment and billing. Extensive computer research involving multiple sites and/or complex hardware/ software procurement or management
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars
- Examples: Conference/ workshop grants but not routine principal investigator (PI) travel
- Projects that focus on the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports)
- Examples: Curriculum development grants; projects to develop electronic reference materials
- Projects that are geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research field sites that are remote from campus
- Consideration given to projects partially or entirely performed off-campus; research conducted at field sites
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications
- Examples: Projects requiring administration of multiple, complex human or animal subject protocols. Single human or animal protocols with routine record-keeping requirements would not meet major project criteria.
Additional Examples
- Competitive, complex procurement (large equipment, fabrication, consultant contracts, etc.)
- Conducting telephone surveys
- Multiple-participant projects requiring coordination and management of consultant contracts, subcontracts and/ or budgets.
- Programs with funding for administrative core activities, such as SCORE and those funded by NIAID
- NIH Program Project Grants and Center Grants
- Extensive interviewing (human subjects, data collection)
- Managing projects with multiple sites
Note: These examples are not exhaustive and should not imply that direct charging of these expenses is always appropriate.
More information
Charging administrative and clerical salary costs as a direct expense
Proper classification of costs & Cost Principles
This is a key component of compliance with federal regulations. Non-compliance may result in financial penalties for UCSD and could affect our ability to qualify for federal funds.
Cost Principles
Cost accounting standards pertain to all awards, federal or non-federal. While terms and conditions of specific awards may differ, the overriding principles that govern campus fiscal accountability must remain consistent. At times, University practice may seem inconsistent with a practice authorized by an agency. If you notice an inconsistency, notify SPF for resolution.
The four cost accounting standards that pertain to UCSD
- CAS 501: Consistency in Estimating, Accumulating, and Reporting Costs This standard ensures that practices used to estimate proposal costs are consistent with practices used to record expenditures against funds.
- CAS 502: Consistency in Allocating Costs Incurred for the Same Purpose This standard describes how costs are allocated.
- CAS 505: Accounting for Unallowable Costs This standard requires that all unallowable costs be identified and excluded from any billing, claim, or proposal under a federal government award.
- CAS 506: Cost Accounting Period This standard describes the cost accounting period, which for UCSD, is the fiscal year, July 1 – June 30.
- preclude a perceived overcharge to the government
- standardize requirements for recipients
- standardize university costing practices
- prevent charging unallowable costs to federal awards