Uniform Guidance, Cost Accounting Standards & Major Projects
Learn about Uniform Guidance, Cost Accounting Standards, and major project requirements that support fiscal compliance for sponsored projects, including when administrative or clerical costs may be considered direct costs.
UC San Diego Compliance
UC San Diego must comply with Uniform Guidance (UG) requirements to support the recovery of direct and indirect (F&A) costs. As required by Uniform Guidance, the university must disclose its cost accounting practices in writing to the federal government.
UC San Diego satisfied this requirement through its Disclosure Statement (DS-2), submitted to the federal government in 1996.
OMB Uniform Guidance
Anyone who authorizes the expenditure of federal funds must have a working understanding of the cost principles established in OMB Uniform Guidance. These principles govern the costs that educational institutions may charge directly or indirectly to the federal government.
UC San Diego generally applies the same cost principles to non-federal funding. However, non-federal sponsors may define or treat costs differently than federal sponsors.
About Major Projects
What is a major project?
A major project is a sponsored project that requires an extensive amount of administrative or clerical support beyond the routine level of services provided by academic departments. For major projects, administrative or clerical salaries may sometimes be considered direct rather than indirect (F&A) costs.
If you are considering charging administrative or clerical expenses directly to a federally sponsored project, see Charging Administrative and Clerical Salary Costs as a Direct Expense.
Major project examples
OMB Uniform Guidance provides examples of projects that may qualify as major projects. The table below includes the federal examples along with additional UC San Diego examples and considerations.
| OMB Uniform Guidance Examples | UC San Diego Examples and Considerations |
|---|---|
| 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. | 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. | 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. | Curriculum development grants and 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. | Projects partially or entirely performed off campus and 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. | 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, such as large equipment, fabrication, and consultant contracts
- 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 involving human subjects or data collection
- Managing projects with multiple sites
Note: These examples are not exhaustive and do not mean that directly charging administrative or clerical expenses is always appropriate.
Charging administrative and clerical salary costs as a direct expense
For major projects, administrative or clerical staff salaries may sometimes be charged as direct costs rather than indirect (F&A) costs.
See Fiscal Polices, Responsibilities, & Compliances for requirements and guidance on when these costs may be charged directly to a sponsored project.
Proper classification of costs & Cost Principles
Proper classification of costs is a key component of compliance with federal regulations. Noncompliance may result in financial penalties for UC San Diego and could affect the university's ability to qualify for federal funding.
Cost Principles
Cost accounting standards apply to all awards, federal and non-federal. Although the terms and conditions of individual awards may differ, the principles governing campus fiscal accountability must be applied consistently.
At times, university practices may appear inconsistent with a practice authorized by a sponsoring agency. If you identify an inconsistency, contact Sponsored Projects Finance (SPF) for resolution.
Cost Accounting Standards (CAS)
The following Cost Accounting Standards (CAS) support consistent treatment, allocation, and reporting of costs.
| Cost Accounting Standard | What it addresses |
|---|---|
| CAS 501: Consistency in Estimating, Accumulating, and Reporting Costs | 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 | Describes how costs are allocated. |
| CAS 505: Accounting for Unallowable Costs | Requires all unallowable costs to be identified and excluded from any billing, claim, or proposal under a federal government award. |
| CAS 506: Cost Accounting Period | Describes the cost accounting period. For UC San Diego, the cost accounting period is the fiscal year, July 1–June 30. |
Purpose of Cost Accounting Standards
Cost Accounting Standards are intended to:
- Prevent perceived overcharges to the federal government
- Standardize requirements for recipients
- Standardize university costing practices
- Prevent unallowable costs from being charged to federal awards