Federal Regulations applied to non-Federally Funded Projects
Some Federal regulations affecting sponsored project apply equally to non-Federally funded projects. This can arise through several mechanisms.
On the business side:
The business community recognizes a number of policies and procedures as "Generally Accepted Accounting Practices".
• Organizations such as the Governmental Accounting Standards Board (GASB) and Financial Accounting Standards Board (FASB) address such standards.
• University finance areas rely on the National Association of College and University Business Officers (NACUBO) to assure that business practices recognize some of the unique needs of Universities.
• OMB's Circular A-21 which governs sponsored project agreements between Government Agencies and Universities provides that: "Cognizant Federal agencies involved in negotiating facilities and administrative (F&A) cost rates and auditing should assure that institutions are generally applying these cost accounting principles
on a consistent basis." A-21 also includes a appendix outlining "Cost Accounting Standards for Educational Institutions." OMB includes an independent body called the Cost Accounting Standards Board (CASB) which deals with the standards that must be applied. A-21requires the filing of an institutional certification of its business practices (DS-2).
In non-business areas, such as those covered by assurances of ethical practices in research (e.g., humans, laboratory animals), most universities extend the principles embodied in such assurances to all sponsored projects.
