Re: Charging for disposal on NIH grants

[Joshua.W.Hamilton@Dartmouth.EDU (Joshua W. Hamilton)]

James Sims recently wrote about IDC coverage of waste disposal:

"For those of you with government contracts like NIH and NSF contracts
or grants, you need to check with your Budgets and Grants Officer about
charging for waste disposal.  The GAO changed the accounting rules on
federal contracts and grants January 1, 1994.  Waste disposal is now
supposed to be considered an indirect cost to such contracts and grants."

I have had detailed discussions about this with our Grants & Contracts
Office, which has also spoken with NIH and other Feds.  Our understanding is
just the opposite of the statement above - the university can carry some, but
not all of the expenses of the Biosafety Office itself (personnel, equipment,
etc.) as indirect costs since the office serves as a "service center," but
the actual costs of waste disposal for individual labs MUST be charged as
DIRECT COSTS back to each project, and cannot be carried as indirect costs. 
The rationale for this is that the costs associated with each individual
research project should be borne by, and readily identifiable with that
project.  The general trend for such services appears to be that more and
more research expenses are going to required to be charged as direct costs,
and less of such services' overhead will be able to be covered as indirect
costs.  At least, that is our situation and our understanding of the current
rules.  Take care!  Apparently a number of universities are going to be
audited this year regarding this specific category of expenses.

Josh Hamilton
Dartmouth College