Watch an eLearning on direct billing of Facilities & Administrative (F&A) costs (approx. 30 minutes).
Federal and UW Policies
The federal government has defined costs as either direct (2 CFR 200.413) or indirect (2 CFR 200.56). Indirect (F&A) costs are those costs “…incurred for a common or joint purpose benefiting more than one activity, and not readily assignable to a single activity specifically benefited, without effort disproportionate to the results achieved.”
For more information on the UW's F&A rates, visit the Management Accounting & Analysis web page on F&A Rates & Costs.
UW’s GIM 23 states that:
- Federally Sponsored Awards: F&A costs cannot be direct billed to a federal Award unless certain conditions are met.
- Non-Federal Awards: F&A costs may only be direct billed if permitted by the Sponsor.
Federal Regulations on Direct Billing of F&A Costs
Federal regulations (2 CFR 200.413 (c)) allow for direct billing of F&A costs on federal Awards under specific circumstances. Direct billing may be allowable when ALL the following conditions are met:
1. Individual costs can be identified and assigned to the Award.
The cost must be easily identified and recorded.
Good: A large mailing where the cost of supplies and postage can be identified and recorded as supporting a single Award.
Not Good: The use of staples which would be very time consuming (if not impossible) and yield very little benefit.
2. Direct billing of F&A costs is explicitly identified in the proposal budget or has the prior written approval of the federal Sponsor.
Costs should be clearly identified and noted as F&A costs being direct billed in the proposal budget and budget notes. If the proposal is fully funded by the federal Sponsor, this identification serves as Sponsor approval.
If it is determined during implementation of the Award that an F&A cost needs to be direct billed, written Sponsor approval must be obtained prior to the cost being charged to the Award. Written approval should include identification of the cost and the rationale for its direct billing to the Award. A copy of the Sponsor’s written approval must be retained on file.
If the Award does not require submission of a budget AND the agency has waived prior approval for direct billing of F&A costs, departments should document that direct billed F&A costs are integral to the Award. The department is responsible for maintaining this required documentation.
3. The costs are not also recovered as indirect costs.
UW’s calculation of its F&A rates takes into account direct billing of some F&A costs. Therefore, departments do not need to be concerned with this requirement as long as they meet the three other requirements listed here.
4. Administrative or clerical activities are integral to the Award.
A cost is integral to an Award if it meets either of the following criteria:
- The objectives of the Award cannot be achieved without the specific cost.
- The Award requires a disproportionate amount of the cost compared to other activities or Awards.
Examples of Activities That May Be Direct Billed
The following are examples of administrative/clerical activities that could be considered integral to an Award and direct billed to that Award:
- Research data gathering
- Research data cleaning
- Laboratory technician activities
- Conducting computer research
- Conducting telephone surveys
- Research training
- Programmatic project effort
- Tabulating research results
- Database maintenance
- Preparing IRB or IACCU protocols
- Preparing progress reports
- Computer programming
- Clinical and patient activities such as scheduling patient visits, processing payments, and interviewing patients
- Writing project manuscripts for publication
- Library searches
- Organizing a conference
- Making travel arrangements for a large number of participants
- Organizing large datasets
- Managing complex projects with multiple sites, especially if there are multiple subcontracts
Examples of Activities That Are Typically NOT Direct Billed
The following are examples of routine administrative/clerical activities that would typically not be direct billed to an Award:
- General departmental administration
- Award proposal development and submission
- Personnel, payroll, and human resources (HR) activities
- Accounting and budgeting activities
- Financial monitoring
- Processing vouchers and payments
- Administrative data entry
- Newsletter/brochure preparation
- Processing and tracking routine purchase orders
- Maintaining departmental databases
- General reception activities
The following are examples of non-salary costs that are normally F&A costs and should not be budgeted or charged to Awards as direct costs:
- Basic telephone equipment and service
- Cell phones, pagers, and related services
- Routine postage and mail costs
- Routine copying and printing
- Repairs and maintenance for state or institution-supported space in UW-owned buildings or facilities
- Office supplies
- Memberships in technical and professional organizations
- Subscriptions to periodicals
- Equipment depreciation
- On-campus space usage
- UW Technology Recharge Fee
The following documentation should be retained if a department direct bills an F&A cost to an Award
- If the direct billed F&A cost was identified in the proposal, retain a copy of the proposal budget and budget notes.
- If Sponsor approval was obtained post-Award, retain a copy of the request for approval and the Sponsor’s written approval.