Justification Nation Part 6: Supplies and Services – It’s All in the Details

beakersWhen Supplies and Services Aren’t Justified Well, It’s Not a Pretty Picture

Research administrators know that justifications for supplies and services, when written well, have a lot of detail. This section in particular is written for reviewers – and is easiest to cut, so the more detail we can provide the better. If a PI does not have a specific research plan, we’re in trouble – now’s the time to ask a lot of questions about exactly what is going to take place and when, so that we can budget the supplies and services that will be needed to support the research plan.

The First Question We Need To Answer: Are The Direct Costs Allowable on the Proposal?

Reviewing the proposal guidelines, the agency guidelines, the appropriate OMB cost principles guidance and our institutional policies, we can determine – with the help of our favorite grants and contracts officer whether or not our PI is proposing costs that are allowed on the proposal. Usually the answer is pretty clear and we can advise the PI if there is a problem.

The Second Question We Need to Answer: Do The Direct Costs Directly Benefit the Research?

If the supplies in the proposal do not directly benefit the research, they belong in the bucket of expenses called facilities and administrative costs – and are not allowed as a direct cost on the proposal. Period. Justifications for unlike circumstances are possible, but as rare as a snow leopard – and be prepared to track those costs once your proposal is awarded. This is a consistency principle of A21.

The Third Question We Need to Answer: What is Our Allocation Method?

Your budget justification should specify your allocation method for using the supplies you propose to purchase on the application. In doing so, this demonstrates your awareness and your PI’s awareness of allocation methods that ensure that proper accounting methods are used when charging sponsored projects, and that you demonstrate a reasonable nature when budgeting for expenses. Principles such as allocating pipettes across projects by usage, or allocating the cost of a large supply expense for an individual over the projects he/she works on indicates a high level of stewardship of federal research dollars. Consistent allocation methods are also key here – and demonstrating that you are following your institution’s policies for charging costs are also important – which demonstrates consistency across your institution.

The Fourth Question We Need to Answer: Are The Budget Estimates We Provide Reasonable?

Describing the basis for your budget estimates is vitally important. Providing enough context to have the reviewer know why the cost basis is reasonable, the components of the activity and each aspect of the cost involved, and the way in which the cost was derived so that it is clear.

Putting it all on the Table (or IN a Table!)

Proposing supplies and services in a clear and straightforward manner almost always includes charts or tables with clear explanations of when costs are incurred, (months, years) how much the costs are, an explanation of the cost, and a listing of the total cost. The clearer we demonstrate the allocation method, and when supplies are going to be used during the research plan, the better we are demonstrating the need for them (and therefore their direct application to the research).

Justifying Unlike Circumstances

 A-21 identifies specific costs that may not be charged directly to research or training sponsored awards, except under special conditions. Unless the special conditions apply, these costs must be paid from a non-sponsored account.  These costs include many of the types of costs addressed in this policy such as administrative salaries, postage and express mail, local telephone, copier costs, general office supplies, etc. There are three criteria under which costs generally considered to be indirect may be allowable as direct costs. All three criteria must be met.

  • Unlike circumstances exist, that is, this particular sponsored award is different from typical sponsored awards.
  • This cost can be associated with the specific sponsored project with a high degree of accuracy
  • The awarding agency has approved charging the cost as a direct cost in this awarded budget.

Got a PI Who Wants to Include A Laptop on A Proposal? Better Yet, an iPad?

Believe it or not, this isn’t my personal favorite (we’ll get to that one in a minute). You can justify a laptop or an iPad on a proposal, but it doesn’t mean your institution will let you keep it on the proposal, or it will be awarded. But you can try!

Circumstances that will assist your proposal:

  1. The laptop is for the implementation of a research intervention and it will be used by a research coordinator, to perform the intervention or to analyze data. 
  2. When not in use the laptop will be kept in a locked cabinet, where only research personnel will have access to it.
  3. The laptop will be encrypted (naturally) and will be password protected limiting its use to the research personnel on the study.
  4. The laptop will not have internet access enabled, or if necessary, will have sites blocked as to prevent Facebook, Twitter, etc uses.
  5. It will only be used off site or in a setting which limits the non-study use of the laptop (if applicable).
  6. For an iPad – the technology of the iPad is needed to implement the intervention or study and the iPad will/will not be enabled with a data package.

Books and Periodicals – It’s Called a Library, People

I’m not kidding. This is my personal favorite – justifying books and periodicals – and it’s a winner. Do you think the auditor can’t find a big building called the library? I beg to differ. To catch you up on why I’m ROTFL, it’s called F&A people – and it’s really difficult to get books and periodicals charged to a grant when they should be charged to the F&A rate for an institution.mainreadingroom_standard

Ask the PI what publications s/he needs to purchase for the grant, and for what purpose:

  1. Check the allowable costs on the FOA – are books allowed? Voila, you’re done.
  2. Check the library’s holdings and see if they are available for the purpose your PI wishes to use them. If they are, you cannot propose to purchase them. If they are not in the library, or are not available for the length of time, or for the audience your PI wishes to lend them to, you can consider including them in the proposal.
  3. Even if the books are not in the library, your institutional policies may still prevent you from requesting books or periodicals on sponsored projects, due to the calculation of F&A rates (it is very difficult to track the individual purchases of books and periodicals on grants, and it is much more effective and compliant to charge these purchases for many types of awards to non-sponsored accounts).
  4.  Circumstances that may assist your proposal:
  • Books and periodicals purchased for the development of trainings and interventions that are used over a lengthy period of time by collaborative working groups (members outside the university, needing more than one copy of the publication for longer than a typical lending period).
  • The purchase of books for training or delivering an intervention that become the property of the participant of the training.
  • It’s better to have proposed to purchase them in the budget justification than to purchase them without having included them at all – so propose them up front – to have the purchase reviewed.

BOTTOM LINE: Justifying supplies and services is about detail, ensuring that the costs proposed relate to the research plan, and are not padded or in fact F&A costs.

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