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The implementation of cost accounting standards applicable to colleges and universities was approved by the Cost Accounting Standards Board (CASB) in November, 1994, following prolonged discussions with the Office of Management and Budget, other federal agencies, and organizations representing institutions of higher education that will be impacted by these regulations. According to the final rule adopted by the CASB, the purpose of the Cost Accounting Standard:
is to ensure that each educational institution's practices used in estimating costs for a proposal are consistent with cost accounting practices used by the institution in accumulating and reporting costs. Consistency in the application of cost accounting practices is necessary to enhance the likelihood that comparable transactions are treated alike. . . . . (and) will facilitate the preparation of reliable cost estimates used in pricing a proposal and their comparison with the costs of performance of the resulting contract.These cost accounting standards became effective on January 9, 1995. After that date, the standards promulgated by the Cost Accounting Standards Board are applicable to educational institutions that receive negotiated federal contract or subcontract awards in excess of $500,000.
Cost accounting provisions have been incorporated into OMB Circular A-21 and "for greater consistency and uniformity" have been extended to all awards--contracts and grants--in excess of $500,000 made to institutions that are major recipients of federal research funds.
Full coverage of the federal cost accounting regulations involves 19 standards which have been applicable since the 1970's in the private sector and for nonprofit organizations that meet the $10 million threshold in terms of government contracts. Only four cost accounting standards will be applied to universities. Briefly, these four cost accounting standards require:
Universities must formally disclose their cost accounting practices. The University of Michigan was among the first group to file the Disclosure Statement and ensure compliance with these standards beginning July 1, 1996.
Adherence to these cost accounting procedures has significant implications for the preparation and approval of budget materials for inclusion in proposals to federal sponsors. The University has to provide assurances: (1) that the pricing of the proposed effort has been undertaken in a manner consistent with the capacity of the University's accounting system to accumulate and report expenditures incurred; and (2) that costs incurred for the same purpose in like circumstances have been treated consistently as either direct or indirect costs. In short, the way that faculty member A in the Physics Department prepares the cost estimates reflected in his or her budget must be consistent with the way in which faculty member B in Mechanical Engineering prepares his or her budget materials.
It is important to note that, while a university can be found in noncompliance only in connection with awards in excess of $500,000 (and as a consequence, be required to make repayments to the federal government for such noncompliance), the consistency in cost accounting practices, in effect, must be demonstrated across-the-board for all activities. Unlike corporate entities that can establish a "government division" to deal only with federal contracts and thereby, limit the coverage of the federal cost accounting standards to that division, the entire accounting and financial management systems of the university are subject to these four standards.