104: General Guidelines
Grant, Contract & Gift Accounting Manual
Section 100: General Administration of Award
- 104-01 Office of Management & Budgets (OMB) A-21
- 104-02 OMB A-110
- 104-03 OMB A-133
- 104-04 Federal Acquisition Regulations (FAR)
- 104-05 OUS-FASOM
- 104-06 OSU Fiscal Operations Handbook
- 104-07 Cost Accounting Standards Board (CASB)
- Cross Reference
All persons associated with a sponsored project are responsible for knowing the applicable regulations, principles, standards and policies. These may include federal polices as well as sponsor, State of Oregon, Oregon University System (OUS), and Oregon State University (OSU) guidelines. These include, but are not limited to, the following:
104-01 Office of Management & Budgets (OMB) Circular A-21 Cost Principles for Educational Institutions
This Circular establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. The principles deal with the subject of cost determination, and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project. The principles are designed to provide that the Federal Government bear its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law. Agencies are not expected to place additional restrictions on individual items of cost. See OMB Circular A-21 (Adobe .pdf document) on Cost Principles for Educational Institutions.
104-02 OMB Circular A-110 Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
This Circular sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants and cooperative agreements with institutions of higher education, hospitals, and other non-profit organizations. For additional guidelines see OMB Circular A-110 on Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education
104-03 OMB Circular A-133 Audit of Institutions of Higher Education and Other Non-Profit Organizations
This Circular is issued pursuant to the Single Audit Act of 1984, P.L. 98-502, and the Single Audit Act Amendments of 1996, P.L. 104-156. It sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of states, local governments, and non-profit organizations expending Federal awards. For additional guidelines see OMB Circular A-133 on Audits of States, Local Governments, and Non-Profit Organizations
The Federal Acquisition Regulations system is established for the codification and publication of uniform policies and procedures for acquisition by all executive agencies. FAR applies to contracts.
The FIS Manual provides the user with policies and procedures applicable to accounting-related transactions at the university. The fiscal policies and procedures apply to all university departments.
The CASB was created by Congress to establish accounting rules and regulations. The Cost Accounting Standards (CAS) Handbook may be obtained by contacting the Office of Post Award Administration at 737-4711. The CAS most applicable to OSU are:
CAS 501 – Consistency in Estimating, Accumulating, and Reporting Costs by Educational Institutions.
This standard requires that cost accounting practices used for estimating costs in proposals be consistent with the cost accounting practices used in accumulating (recording) and reporting costs. The standard is designed to provide a basis to compare proposal cost estimates with the actual costs. In its simplest terms, the standard requires that if costs are included in the project proposal, they must be accounted for as project costs; this includes cost sharing. When salaries are charged, effort reports must tie with accounting records (including any cost transfers), with proposal budgets, and with all progress reports to the sponsor.
CAS 502 – Consistency in Allocating Costs Incurred for the same Purpose by Educational Institutions.
This standard deals with consistency in accumulating like costs incurred for the same purpose. It requires that each type of cost be allocated only once, and on only one basis to any contract or other cost objective. The institution must identify which costs are charged (1) only as direct, (2) only as indirect, or (3) both as direct and indirect. In its simplest terms, the standard requires that cost coding must consistently identify like costs in like circumstances as always direct or always indirect. If a contract is charged directly for a cost, the same type of costs should not be in the F&A rate, and vice versa.
CAS 505 – Accounting for Unallowable Costs – Educational Institutions.
This standard contains guidelines on consistency in identifying unallowable costs and how they are treated within the cost accounting system. The standard does not provide additional guidance on what is unallowable; educational institutions will still follow OMB Circular A-21. In its simplest terms, the standard requires that costs expressly unallowable under OMB Circular A-21 or mutually agreed to be unallowable under terms of the agreement must be identified and excluded from any billing, claim, application, or proposal applicable to a sponsored agreement. Detailed records should establish and maintain visibility of identified unallowables, including allocation and cost accounting treatments.
CAS 506 – Cost Accounting Period – Educational Institutions.
This standard requires that the cost accounting period and all costing information (both direct and indirect) is based on the same period as the institution’s fiscal year. For OSU that period is July 1 to June 30.
See GCG 407: Reference Websites for specific agency information and other website references.