Explaining Unlike Circumstances

The primary concern is that costs that should be covered by indirect costs should not be paid out of direct costs without specific approval for “unlike circumstances” from the sponsor.

Grants with expanded authority may move costs between budget categories without prior authority unless such a move constitutes a move from indirect to direct costs.   Approval must be granted either in the application itself or a concurrence letter sent after the fact.

If the application includes a modular budget, costs of concern should be justified as part of the “other budget justification”

Refer to NIH grant policy for expanded authority: http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part7.htm#_Toc54600128

Costs of concern

Regular monthly phone services

This includes 1-800 numbers, pagers, cell phones, dedicated phone lines, and any other regular monthly service. 

This does not include long distance.

Explain unlike circumstances by explaining the project has a special need for the item and why existing services paid for by the department will not work for the project.  Reiterate that the university has the capacity to bill project-specific charges separately so they will not be co-mingled with regular phone costs.

Routine copying

This includes incidental copy jobs of budget projections, reports, or anything that makes up a few pages each. 

This does not include project-specific large scale printing jobs whether sent to UW services or on the department copier.  This also does not include off-campus projects where there is no access to the department copier.

Explain unlike circumstances by listing the large-scale projects that will be paid for: large quantity of human subjects forms, manuals, meeting materials etc.  Include information that reflects the scale of the projects and explanation why the special need would significantly exceed the quantity routinely provided by the department.

Administrative support

This includes support for purchasing, routine budget monitoring or other fiscal management.

This does not include project-specific support such as research coordinator conducting patient recruitment, processing study data, preparing questionnaires, databases or web interfaces, etc.  (See GIM 23 Attachment A for a list of Job Class codes that are considered Administrative and Clerical: http://www.washington.edu/research/osp/gim/gim23a.html)

Explain unlike circumstances by listing the project-specific duties, percent of effort and salary. Explain why the work performed under this particular project requires an extensive amount of administrative or clerical support which is significantly greater than the routine level provided by the department. Allowances generally are made for large, complex grants, large centers, large grants affiliated with centers or clusters of related grants.  Even if the application makes it clear that the circumstances allow fiscal or administrative support, the details of the work must be outlined in the justification.

Refer to GIM23, section II. A.B. on the definition of Direct and Indirect Costs: http://www.washington.edu/research/osp/gim/gim23.html