Can you explain what accounting principles are necessary to demonstrate that unallowable charges are not being absorbed by NIH funded research, e.g., indirect costs?
The cost principles contained in OMB Circular A-21, http://www.whitehouse.gov/omb/circulars/a076/trans21final.html particularly with regard to treatment of allowable and unallowable costs, contain the necessary guidance. Federal policy is explicitly clear that no Federal funding may be used, either directly or indirectly, to support human embryonic stem cell research outside the criteria established by the President on August 9, 2001, i.e., it is unallowable. Therefore, the direct costs of such work must be charged only to non-Federal sources of funding. With respect to indirect costs, also known as facilities and administrative (F&A) costs, institutions engaged in unallowable stem cell work must be able to demonstrate that none of the costs of supporting this work have been included in the rates established and used to charge F&A costs to federally funded research.
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