ARRA Administration Costs are all Indirect

I had a conversation some time ago with my Division Chief here at BICO explaining why he could not budget (DC) for someone to handle the ARRA reporting and administrative requirements (special admin costs may become direct when the science itself requires them, such as for large survey research – not when the terms of award do). More recently, the NIH has come out with a clear statement for all those other PIs trying to sneak some ARRA reporting support into their grant personnel costs:

Can ARRA grant budgets include direct costs to address ARRA administrative and reporting requirements?

No. It has been determined that ARRA requirements do not provide sufficient justification to support the provision of direct costs for administrative support in addition to the Facilities and Administrative (F&A) costs in the awarded budget.

NIH staff will continue to evaluate direct costs requested for administrate support using the guidance provided in OMB Circular A-21 F.6.b.(2). However, ARRA requirements will not be considered in this determination, because they are incorporated within the core administrative support for the project, which is reimbursed to the institution through the provision of F&A costs.

When direct costs have been requested to address ARRA administrative and reporting requirements in requested budgets, NIH staff will make appropriate adjustments. Revised budgets submitted solely to remove administrative costs will not be accepted.



  1. D said

    Sneaky PIs. Do they really need to hire someone to file 4 extra reports/year? It is a mild burden but still.


  2. This is very interesting, as about a month ago, we received an e-mail from our grants office instructing us to include a specific amount for these expenses in our ARRA direct cost budget, and stating that The Council on Governmental Relations was discussing the issue with OMB and was optimistic that such expenses would be allowable direct costs. Looks like they were wrong.

  3. BB said

    Now I’m so confused. I included a percentage of someone’s salary for labwork and for ARRA tracking/reporting in my RC1 submission. Am I screwed?

    No, assuming you specifically noted this in your budget justification, per the FAQ response above, the NIH will ask you what percentage of time is for labwork versus ARRA administrative duties and reduce the budget accordingly. – writedit

    • D said

      No, you are not screwed. If you get a fundable score NIH will just adjust your budget down by removing those dollars for ARRA reporting tracking.


  4. RGP said

    On the topic of indirect costs — office supplies also fall under indirect costs, correct?

    Our Dept has put a freeze on purchasing all office supplies even though our College does receive indirects from all of our NIH grants — had to beg for some paper this morning to put in the printer….eventually got some but it was worse than pulling teeth out of grumpy, bad-breathed chihuahua.

    Is this just us or are other institutions refusing to to use indirects for office supplies?

    On the positive side, I guess I could try to view this as going green.


  5. D said

    The simple answer is that, generally office supplies, are indirect costs. But, it gets tricky. A good powerpoint is here.

    You would need to see the negotiated F&A agreement between your school and the Federal gov’t to know for sure.

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