Guidelines: Budgeting & Expensing Genomic Arrays on NIH Awards

NOT-OD-10-097 released by NIH in May 2010, provides guidance on the transformation from customary costing principles and procedures for the treatment of this specific supply (GA) through the application of the Facilities and Administration (F&A Rate), also known as the Indirect Cost Rate. For purposes of this policy, the term F&A Rate will be used. The budgeting and reimbursement approval of these costs require careful consideration to ensure that these substantial investments are both scientifically and fiscally justified. The application of F&A costs when budgeting and for reimbursement purposes will be limited for GA as a "high-throughput commodity and service."

This notice states that institutions may earn overhead on the first $75K spent on GAs per budget year and that any funds expended in excess of $75K for that budget year be treated as non-overhead-bearing. In order to simplify the accounting for this new rule, we have identified two new object codes for use when paying for genomic arrays: 6695 (specialized lab supplies, overhead-bearing) and 6696 (specialized lab supplies, non-overhead-bearing).*

Procedures For Genomic Array (GA) Supplies and Services on NIH awards:

When budgeting for each project year: First $75K specialized supplies or services, overhead-bearing >$75K specialized supplies or services, non-overhead-bearing

When expending in each project year:

First $75K: object code 6695 (specialized lab supplies, overhead-bearing)

$>$75K: object code 6696 (specialized lab supplies, non-overhead-bearing)

*Because Harvard will use specific object codes when budgeting and paying for genomic arrays, we may disregard the advice in the NIH Notice to budget and expend for GAs in a manner similar to subcontracts.