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FROM ONE NON-PROFIT TO ANOTHER: PLAYING BY THE RULES. Lillie Ryans-Culclager – SRI International Ken Merritt – Stanford University. What are the Rules?. Grantees must comply with Federal Principles OMB Circulars A-21 or A-122
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FROM ONE NON-PROFIT TO ANOTHER:PLAYING BY THE RULES Lillie Ryans-Culclager – SRI International Ken Merritt – Stanford University
What are the Rules? Grantees must comply with Federal Principles OMB Circulars A-21 or A-122 OMB Circular A-21 - Principles for determining the cost applicable to R&D, Training, and other sponsored work performed at Colleges and Universities OMB Circular A-122 - Establishes principles for determining costs that are allowed to be charged to Federal grants, contracts, and other agreements with non-profit organizations (except educational institutions)
More on A-122 • FAR 31.2 – Principles applicable for determining costs of grants, contracts and other agreements with commercial concerns; and, Cost Accounting Standards 405, and Generally Accepted Accounting Principles, if appropriate to the particular circumstances. • what the government will reimburse on cost contracts and what costs it will recognize in negotiating fixed‐prices • Applies to some non profits because the size and nature of operations are similar to for profits
Collaboration between institutions • Carrying out activities in conformance with applicable federal requirements • Partners must accept that there is no “free lunch” • When organizations receive federal funds, It is essential to comply with laws and regulations.
Applicability is dependent upon: • Differences exist in the specific requirements • Public or private status • Governmental versus Nongovernmental subrecipients • Non-profits vs for profits • State and local governmental agencies
Hierarchy of Regulations Hierarchy of Regulations Legislation (LAWS, Federal and State) Program & Administrative Regulations(Codified regulation including A-21, A-122, A-110, FAR 31.2, and Specific Policy Manuals) Institutional Policy Terms and Conditions (incorporates the authorities above)
Cost Principles Defines Allowability • Costs that may be partially allowable, or require special consideration depending on particular conditions or circumstances • Exclusion does not mean that it is either allowable or unallowable • Look to treatment for other similar costs addressed in the cost principles