Capitol Hill Showdown: What Will October Bring?

preparationI don’t know about you, but when I’m working on an application deadline, I’d like to think about helping my investigator submit a quality application – not whether the government will be open for business to accept the application on the due date.

Unfortunately, it’s mid-September, so that means our elected officials are squabbling again about whether or not they’d like to fund the federal government through the end of the calendar year.

Unfortunately, this political tango has very real consequences for scientific research – both the currently funded kind, and the research in-need-of-support kind. And for this go-around, we have another hurdle to face with an anticipated battle over the definition and scope of the debt ceiling. Our national legislators are seeking to tie this discussion to other mandates, such as reducing or eliminating funding for the Affordable Care Act, or adjusting the terms of sequestration. Regardless of the outcome, the effect is likely to create uncertainty in federal agencies, and if it goes on too long, could lead to belt-tightening.

This drama is likely to play out during the last few days of September, when Congress considers legislation to fund the President’s 2014 budget, or not. For the past 5 years, we have funded the government on continuing resolutions, which are a series of appropriations bills that have passed both houses of Congress and been authorized to fund the nation’s work for a period of time (from weeks to months, to a year). These appropriations bills are sometimes cobbled together and approved in chunks.

After we pass the first hurdle of keeping the government running (and can submit our applications), we must address the debt ceiling hurdle – which has a decision deadline of October 15, after which the Federal government goes into default on its financial obligations, and cannot pay its bills, such as student loans and Social Security checks. There is some discussion that prudent management of the deficit has given the Treasury some wiggle room for the November 1 pay period, but agencies that have “discretionary” payments are already starting to look at the next couple of months and plan for a battle in Washington.

The political environment is even more complicated – a primary election underway in the state of Kentucky has effectively silenced Senate Majority Leader Mitch McConnell as a more moderate force between Democrats and Republicans in the Senate (as was the case during the last debt ceiling debate in 2011). Similarly, House Speaker John Boehner is in a difficult position between a very conservative wing in the House that is attempting to de-fund Obamacare as a condition for raising the debt ceiling and keeping the government open – which if the government shuts down, may cost him his Speakership.

What does this mean for research administrators?

If you are waiting for a non-competing continuation, a subcontract, or a notice of award – don’t hold your breath. Everyone is going to be in a holding pattern until this is sorted out. If your investigator decides to start work, be prepared to open pre-spending accounts, and direct charge expenses (conservatively) until you know what your funding will look like. Encourage your investigators to talk to their program officers and get a read on what’s going on at their funding agency. Monitor activity and costs closely to manage potential cost share commitments until funding comes through. Keep your PI’s and departments updated on developments – and while you’re at it, load up on the antacid.

Buckle up. It’s going to be a bumpy ride.

Subcontractors, Consultants and Vendors: So Many Choices, Still So Confusing.

hire.outsource image

There are more proposals to submit to agencies than ever before – and the criteria for competitiveness includes an institution’s ability to collaborate – not only within its walls but with investigators working on related research at other institutions.

The selection of the proper agreement type for a collaborator during the proposal phase should happen as early as possible, with the investigator working with the research administrator and the collaborator to evaluate the proposal mechanism and the statement of work. A set of questions help evaluate the best agreement for the collaboration.

What criteria determine the type of agreement for a sponsored project?

1. What is the service, function or activity they will perform (with some specificity).

A subcontractor or consultant will typically have a more detailed scope of work than a vendor, which has a very specific task to perform. A subcontractor and consultant perform work which relates to the aims of the award, which have milestones and reports attached, and often require analysis. However, the outcomes of the work are not predetermined. A vendor’s work is determined by its regular course of business as it is contracted to perform a service on behalf of the award, and it either performs the service, or it does not.

2. Under what time frame will they perform it?

Accordingly, the time frames for the agreements will match the types of work performed. A vendor is usually engaged until it finishes the work performed.

3. Will they be using the facilities of an institution, or their own facilities?

Subcontractors and vendors use the facilities of their institutions; consultants use their own facilities, and not the facilities of their institutions (unless they are a small business).

4. Who will the check be made out to (who will receive the 1099)?

A subcontractor and vendor will have payments made to an institution. A consultant is almost always an individual, but can be a business. In the event that a consultant is a business, this arrangement should be reviewed periodically to ensure that the agreement should not be revised to become a subcontract in subsequent years. (Yearly consulting agreements should be considered.)

5. Does the contractor expect to have publication rights?

Only if the contractor is a subcontractor. A consultant does not typically receive publication rights.

6. Will the work of the contractor affect the direction of the science in some way?

Only if the contractor is a subcontractor. A consultant does not typically have the ability to influence the direction of the science, as the role of a consultant is to produce a work product under the direction of the PI but does not have a named scientific role. If the individual is to direct the science, they should work under the auspices of their academic institution and contribute based on their institutional based salary/effort.

7. Is the contractor working in a capacity with a level of independence?

A subcontractor or consultant, based on their named role on the project has the ability to function independently with oversight by the PI. A vendor cannot function independently. They have a scope of work that they need to complete under the direction of the PI by a specified time frame, and there is no room for deviation or independence.

8. Do the terms of the award flow down to the contractor?

The terms of the award flow down to the subcontractor and the consultant, but not the vendor. This may be a vital distinction when selecting a correct agreement type for a collaborator.


I’m very appreciative, but often surprised when an investigator suggests setting up a subcontract after the fact to “save work” and time, because it seems too cumbersome to set it up during the proposal phase. In fact, setting up the subcontract, consultant or vendor agreement during the proposal phase is crucial – because at that time, F&A is being established based on the proposal budget. When the proposal is awarded, and F&A is set – any after the fact subcontracts or other agreements have to include F&A out of direct costs. This is a VERY painful budgetary impact that could have otherwise been avoided.


When the collaborator is a subcontractor, we have a standard package of materials that we send from our institution that we hope will make life easier for the research administrator we are working with, who will almost always be receiving the request (we ALL know this) later than we would like.

  • Northwestern’s subcontractor form (Financial Conflict of Interest Statement with standard SF424 info)
  • Draft Budget and Budget Justification
  • Draft Statement of Work

For a consultant, we provide a draft consultant letter, which states the hourly rate of pay, travel per diem, length of time work will be performed, nature of the work to be performed and support for the project. We also provide detailed instructions for completing our FCOI process for the proposal.

Common Question: Can a consultant on a proposal be an investigator at my institution?

If the work on a sponsored project is not related to an investigator’s regular work, and is not an ongoing assignment, it may be possible to justify a consulting agreement at your institution for an investigator who is also employed by your institution. However these agreements require prior institutional approval before they are proposed and should be done with proper planning. A PI cannot propose an investigator in the same department as a consultant.

Be a Spreadsheet Superhero!


It’s the heart of every budget – the spreadsheet. How it is written and constructed sets the course, not only of the few weeks it takes to submit the proposal – but of the years it takes to manage the project when it is funded. The spreadsheet starts off innocently enough, as a draft that one or two people (usually the PI and the research administrator) work to edit as the proposal is constructed. Carefully planned and well constructed – this can be a time when decisions are made, and documented to set the life of the project off on the right course. Or…not.


It’s quite common to learn research administration from the inside out – that is, you join a project mid-stream, and pick up the documentation that a previous team generated for you to work with. That means that your success in helping to administer the research in a department or division depends on the communication that has been left for you by the previous RA, and the internal budgets you’re responsible to manage. It’s more than just written communication – it’s the budget spreadsheets that allow you to help guide your investigators to make decisions about how their projects will be managed in the coming project period.


So how does one become a spreadsheet superhero? It requires some practice and dedication, and a commitment to consistency – knowing that you’ll be serving your investigators long after you leave your position and move on to your next job if you take on this alter ego.


1. Always use formulas and references when budgeting in Excel. Hard enter numbers only when absolutely necessary. Make your spreadsheets work for you, and your investigators.

2. Ask your colleagues for the best budget spreadsheets out there – and if one doesn’t exist (rest assured it does) create one. Find one that works best for your investigators’ applications and use it consistently. Time and date stamp it. Improve it as you use it for each application.

3. Budget based on institutional base salary. If you don’t know what institutional base salary is for your institution, find out. If your spreadsheet doesn’t start or takes you off course from the IBS at your institution, you will be managing cost-sharing on the award if it is awarded.

4. Try very hard to help your investigators to break the habit of doing their own budgets. You can draft them and let them play with the numbers. Many investigators forget elements of budgets – and others don’t understand why certain costs need to be included. In all cases, they need to focus on the science, and that’s why we’re there, to help with the administrative aspects of the application. It’s hard for them to depend on us. Try to help them learn to depend on you.

5. Check your math. Have a colleague review your budget and justification, just to make sure. These things are often developed very quickly and often under pressure. It’s easy to make transposition errors, etc. Have someone with fresh eyes who has had a bit more sleep take a look at your work.

6. Spend a lot of time on the budget justification. Flesh it out for the PI, to help explain the nature of each expense. Include an explanation of the calculations involved if there is a question about how the funds are to be spent.

7. Include the names of individuals working on the project in your budget spreadsheet – even if they are not included in the official proposal documents. Simple details like this are very helpful when administering salary on funded projects.

8. When creating budget spreadsheets, put yourself in the recipient’s shoes – what does the reviewer need to see? Present the budget with that in mind and keep it clean and tight. Present supporting information in sheets behind the summary page of the workbook, linking totals to the summary page. Crowding everything into one page dilutes the information you are providing and adds to the reviewer’s job. (It can also increase the chance of error and cost-sharing.)

9. Use your spreadsheets consistently – for applications, award management (clinical trial tracking, grants management, contract management, salary and effort management, and reporting to investigators). Create roll up reports to identify areas of concern (projected deficits) and manage no-cost extensions prior to them coming due.

10. Create a shared repository for this information for the investigators you work with, as well as the business administration team and central office staff you interact with. As you maintain these records, they will serve to document the active management of your investigators’ activities, help you manage their awards, and hand off their accounts easily to the next person who steps into your role. And that’s customer service!

It’s not easy to keep up with these types of records, especially when things get busy – but its harder not to – especially when there is a need for the information. Take the time to learn Excel well, and share your knowledge and time with your colleagues. Spend the time to develop the systems and processes to support your investigators and develop the spreadsheets that will serve you – and them well – now and far into the future.

Justification Nation Part 9: The Hard Truth – A Budget Justification Is Never Fully “Approved”

A21Expenses are Not 100% Allowable Until they Are Approved by the Grants Management Specialist

The budget justification is required in order to demonstrate that the research plan and budget are closely aligned and that the proposed expenses are reasonable.

However, the investigator can propose a research plan, budget for it, and receive funding. The program officer can even approve the investigator’s activities and ideas, and encourage him or her to proceed. But the investigator can still be told that it is not possible to charge the project for expenses that were proposed (and previously “approved”) when the charges are reviewed by the grants management specialist for the award.

Why does this happen?

  1. At the proposal stage (when the institution submits the application) the institution reviews the application guidance against the science and submits what it believes to be the most compliant proposal to the agency but the agency needs to confirm that the proposal meets the guidelines.
  2. The proposal is received by the agency (if it is a federal agency) and typically reviewed by a scientific panel to be approved on the basis of its scientific merit, and whether or not the budget is appropriate to achieve the scientific aims. (Is it realistic or not – not whether the items proposed are compliant with A21.)
  3. The investigator receives approval for the application and will receive a preliminary budget review, and may be asked to re-budget (if there is a funding reduction) and at that time, some items may be found to be unallowable.
  4. The investigator will start work, and then the grants management specialist or other financial manager will work with the research administrator to evaluate certain transactions while the research project takes place. This individual, along with the university grants and contracts financial specialist, has a key role to play in the accurate financial management of your account and whether or not a charge is allowable on the award.
  5. An auditor of an award also evaluates allowable charges and has the ability to determine whether a charge can stay on the account or whether it has to be removed.

What Can A Research Administrator Do To Help Support the Justification of Allowable Costs?

  • Write complete budget justifications, don’t cut corners. (Don’t provide too much information – know the type of information required for each type of cost and be complete – in order to ensure that you can document the basis of each cost when it is needed.)
  • Maintain documentation for proposals (budgets and budget justifications) as well as proper version controls in an easy to find electronic filing system. Follow the “hit by the bus” method (if you were hit by a bus – could someone step in to your role and find everything you were working on? Would they understand the naming conventions for your files?
  • Maintain the justifications for changes, decisions, re-budgets, allocation methods, using a system that is easy to detect.
  • If you’ve dealt with any sort of issue, document how you handled it, and provide documentation for your central office.
  • Work with your central offices (sponsored research and accounting offices) to problem solve grants management questions when they arise before working with the funding agency. Develop and maintain all documentation related to the interactions related to questions related to allowable costs.

Documentation that links the science to a proposed cost – and then the decision that supports the cost and whether it is an allowable charge on the sponsored project is the end result of our activity. If there is any break in this chain – something that makes us question the allowable cost, our need to document the discussion and decision to charge the sponsored project is paramount.

Helping our investigators understand that this process is never truly complete – because their work is evolutionary by nature – is important. As research administrators, we can assist our investigators by maintaining our follow up, asking questions about the status of their projects.



Justification Nation Part 8: Other Direct Costs – A Few Items Like Tuition Remission, Animal Care Costs, Human Subjects Costs, and Consultants

Other Direct Costs

It sounds like a category for a few leftover items, things that are not as important, but that’s far from the case. Tuition remission costs, animals and animal care, human research participant costs (as well as patient care costs), shipping research samples and equipment, and consultant payments are some of the main budget items that are included in this section of the budget and budget justification.

Laboratory mouseTuition Remission

According to OMB Circular A-21, tuition remission for students is an allowable direct charge on federal grants and contracts provided that the following conditions are met:

  • There is an employee-employer relationship between the student and the institution for the work performed;
  • The tuition remission is a reasonable compensation for the work performed and is conditioned explicitly upon the performance of necessary work; and
  • It is the institution’s practice to similarly compensate students in non-sponsored as well as sponsored activities.

For the NIH, the graduate student compensation limit is the NRSA zero-level post-doctorate stipend level when budgeting tuition. Check your institution’s policies when justifying your school’s stipend and tuition level’s if they are higher than this rate. The NIH guidelines ask you to include your school’s tuition rates.

Animals and Animal Care

Providing details about the animals and animal care costs (mapped out against the research plan) helps the reviewers to see how well the investigator has planned and estimated the costs of his or her research. Include costs of any animals that need to be purchased, and the per diem rates for the animal care facility. If the research plan has any unusual features (unusual procedures, follow up time, etc) its best to explain in this section if there are costs involved that are related to the research plan.

Human Participant Reimbursements/Research Patient Care CostsMedical Student

Few research studies accrue patients right out of the gate, and have steady accrual rates. In addition, complicated protocols with multiple visits and payments for participation require an elegant justification which clearly outlines the payments to research participants on the timeline that reflects the participation of subjects mapped out against the research plan.

Understanding this – having the PI explain it to you and refine it with you is key. I’ve seen some payment tables for research subjects that remind me of what it must be like to direct the air traffic control center at O’Hare airport, they are that complicated. But that’s what it takes to justify thousands of dollars in participant  payments.

BY THE WAY…Don’t even think about calling these payments an honorarium or an incentive. The institutional review board, the local review board that reviews the study and ensures that we are protecting human subjects, does not want to see that we are considering these payments an incentive for participation. The dollar amount of these payments should not be coercive (it should reflect the real, reasonable cost of what it means to participate in the study – to truly be a reimbursement of their time) and should not act as an incentive for them to participate.

If you are budgeting research patient care expenses for a clinical research study, you should include the following information in your budget and budget justification:

  • The names of any hospitals and/or clinics and the amounts requested for each.
  • Provide detail for inpatient and outpatient costs separately.
  • Provide cost breakdown, number of days, number of patients, costs of tests/treatments.
  • Justify the costs associated with standard care or research care.


Consultants are individuals or small companies providing a specialized service to meet an aim of the sponsored project. The consultant usually charges a rate by the hour or by the day, and does not use any resources of the University in order to deliver services to the project. The consultant does not exercise any discretion over the project’s direction or aims, and once the consultant delivers his/her services the consultant’s work is complete.

To budget and justify a consultant on a sponsored project, your institution may have a standard form (the consultant is held to the financial conflict of interest regulation that NIH and NSF have recently established) but the federal flow through terms do not apply to a consultant agreement, who is treated like a vendor.

To budget a consultant on an award, draft or obtain a letter from the consultant that states the following information: (Check out my previous post on subcontractors and consultants on budget justifications)

  • Intent/availability to work on the project (dates) and support of the project.
  • Hourly/daily rate of pay
  • Time frame for completed work
  • Statement of work they will perform
  • Travel needed to perform work

Include the basic information on the budget justification and attach the letter to the application. Careful attention to the Other Costs section can ensure that these costs are fully accounted for and funded when the budget and justification is reviewed by the agency.

Justification Nation Part 7: Leaving on a Jet Plane – Budgeting Travel on Sponsored Projects

TicketsBudgeting travel on sponsored projects used to be a reflexive activity. Not anymore. President Obama’s executive orders in the past several years have made budgeting travel a very careful exercise. Travel still occurs quite regularly on sponsored projects,  but your justifications for travel expense should be presented with great care.

Budget requests must separate travel into “domestic” (which includes the United States and its possessions, Puerto Rico, Canada, and Mexico) and “foreign” categories and include requests for travel to conferences, fieldwork or related research activities.


Every sponsor expects that the research team will share its preliminary findings or progress at a research conference – this is part of the dissemination plan. It’s important to ensure that individuals who attend these meetings have an active role in presenting the data.

You’ll want to be familiar with the provisions of the Fly America Act and the Open Skies Agreement when budgeting and charging federal grants for travel, which requires air travel to be booked on US-based carriers or approved air partners. As a general rule, a domestic conference for one person, on average, costs approximately $1,500; an international conference, approximately $2,000-$2,500. This budget estimate is for three days, and includes an average per diem, hotel, and cost for an airline flight.


For field work and other research-related travel (collaborating with researchers at another institution, for example, or projects at a national laboratory or other external facility), you can generate a detailed budget for all expenses related to the travel, including airfare, ground transportation, mileage, car rental, living expenses, per diem rates for meals and other expenses related to the work they will be doing.

travelNote that for work done in certain areas of the country or certain areas of the world, the per diem rates are adjusted (check the GSA website and your institution’s policy) and if your investigator will be traveling to a dangerous part of the world there is a budget consideration for that as well – it’s on the State department website (there is a budget factor depending on what area of the country may be affected by political problems or war). These charges are acceptable to include on the grant and should be mentioned in the budget justification.


In this environment of limited sponsored research funding, it’s really important to be creative with meeting costs and limited travel dollars. Many investigators want to have research meetings in person, when that’s not always possible. You can suggest several alternatives:

  1. This idea is not new, but it is helpful: pick a meeting in the field of research that your PI and his or her collaborators regularly attend each year and hold a research meeting while everyone is already in attendance.
  2. Use video conferencing or SKYPE to link collaborators face to face on a regular basis.
  3. Use conference calling to discuss research progress on a regular basis; there are free conference calling services available.

A judicious use of travel dollars will allow your research funds to be used for salary and other expenses, and will be highly valued by reviewers!

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.