University of Vermont

Cost Accounting Services

Cost Accounting Standards Justification Documentation

When costs are assessed as being incurred in unlike circumstances, the Principal Investigator shall submit a completed direct charge justification form and receive approval before any normal indirect cost may be direct-charged to a federal sponsored agreement or federal formula grant.

Proposal Stage – Direct charge justification shall be submitted along with the completed proposal package. For approved indirect costs to be charged as direct costs during the proposal stage, a subsequent justification form during the post award stage is not required.
  • For sponsors requiring a budget and/or budget narrative for proposals, the cost must be specified in the proposed budget of the sponsored agreement and/or the unique circumstances requiring direct charging are justified in the proposal narrative. In these cases, the sponsoring agency must approve (i.e. does not specifically disapprove) the direct charging of the cost as part of the sponsored agreement’s award documentation.
Post-award Stage – Per the University’s procedures, a direct charge justification form shall be submitted for any indirect cost not originally approved as an unlike circumstance as part of the proposal and is deemed a requirement to conduct the technical scope of a federal sponsored agreement.

Record Retention – Approved justification forms shall be considered supporting documents of a federal sponsored agreement and will be retained centrally. Federal record retention and access requirements apply (OMB Circular A-110).


Last modified March 20 2012 03:25 PM

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