Unlike Circumstances: Budget Direct Costs Normally Classified as Indirect Costs

An unlike circumstance occurs when a cost that is typically treated as an indirect cost is significantly greater or different in purpose than what is routinely provided by an academic unit or department. 

Typical Costs Include

  • Administrative/Clerical Expenses
  • General Supplies
  • Memberships and Subscriptions
  • Other Electronics
  • Phones
  • Postage 

Federal Cost Accounting Standards (CAS) establish the types of projects and activities where it may be appropriate to budget indirect costs as direct costs. This is called a CAS Exception.

These Projects and Activities Include

  • A large, complex program such as a general clinical research center, primate center, program project, environmental research center, engineering research center, or other grant or contract that entails assembling and managing teams of investigators from a number of institutions.
  • A project that involves extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as an epidemiological study, clinical trial, or retrospective clinical records study).
  • A project that requires making travel and meeting arrangements for large numbers of participants, such as a conference or seminar.
  • A project whose principal focus is the preparation and production of manuals or large reports, books, or monographs (excluding routine progress and technical reports).
  • A project that is geographically inaccessible to normal departmental administrative services, such as a research vessel, a radio astronomy project, or other research field site that is remote from campus.
  • An individual project requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; or multiple project-related investigator coordination and communications.
  • A project which is funded from non-federal funds and where not expressly prohibited by the sponsor.

If none of these projects apply, then the cost does not qualify for a CAS Exception and the cost cannot be budgeted as a direct cost.

If the project does apply, take these steps to properly document the exception.

  • Ensure the unique/unlike circumstances of the project are clearly supported by the proposal.
  • Include the cost(s) in the proposal budget.
  • Fully justify the cost(s) in the budget justification.

Tips to Fully Justify an Exception

Administrative/Clerical Expenses (See Administrative and Clerical Salaries (DOC))

Phones (See Telecommunications Costs (DOC))

General Supplies
  • An explanation as to why the general supplies are necessary to complete the scope of work.
  • A detailed justification of the supplies needed and how they will be used for the project.
  • For projects that need scientific software, a confirmation that the software requested is not readily available for download through NIU.
  • A discussion as to what is unusual and/or unlike about project scope that the academic unit’s resources are insufficient.
  • An explanation as to how the PI or research team will track the usage of general supplies to ensure they are not used for other activities.
  • Any additional information that would strengthen the budget justification and further explain the unusual need or unlike circumstances for the general supplies.
Memberships and Subscriptions

To qualify, both of the following must be true:

  • The scope of work/research makes these items necessary to meet the project objectives. 
  • The membership or subscription will be used exclusively for this project. 

If true, an exception may be allowable, and the budget justification must explain all of the following:

  • A detailed justification of what the purpose of the membership or subscription is.
  • An explanation as to why the membership or subscription requested is necessary to meet the project objectives.
  • Affirmation that the membership or subscription will be used solely for this specific project.
  • Any additional information that would strengthen the budget justification and further explain the unusual need or unlike circumstances for the membership or subscription.
Other Electronics (Non-Computing Devices)

To qualify, both of the following must be true:

  • The scope of work/research makes these items necessary to complete the research. 
  • These items will be used exclusively for this project. 

If true, an exception may be allowable, and the budget justification must explain all of the following:

  • An explanation as to what role these electronic items will have in the project that makes them necessary to complete the scope of work.
  • A detailed justification as to how many items will be needed, how many people will use them and for what purpose.
  • An explanation as to how the PI or research team will track the usage of the GPS, camera or other electronics to ensure they are not used for other activities.
  • Any additional information that would strengthen the budget justification and further explain the unusual need or unlike circumstances for the GPS, camera or other electronics.

See separate guidance for charging small computing devices.

Postage

To qualify, one or more of the following statements must be true:

  • The scope of work/research requires that postage be used for mailing out surveys, participant letters, etc. 
  • Postage is necessary to complete the goals of the project.
  • Postage is required at amounts significantly greater than the routine amounts of postage provided by academic units.

If true, an exception may be allowable, and the budget justification must explain all of the following:

  • An explanation as to the purpose of the postage and why it is necessary to complete the scope of work.
  • For projects that require postage for mailing out surveys or letters, a detailed description as to how much postage is needed.
  • An explanation as to how the PI or research team will ensure that the postage is not used for any other activities.
  • Any additional information that would strengthen the budget justification and further explain the unusual need or unlike circumstances for the postage. 

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