The document “DCA Best Practices Manual – COGR Interpretations” provides a comprehensive analysis of the Division of Cost Allocation (DCA) Best Practices Manual, focusing on its implications for Facilities & Administrative (F&A) cost rate proposals at colleges and universities. Produced by the Council on Governmental Relations (COGR), the report positions the DCA Manual as a significant, though non-binding, reference in F&A rate negotiations and emphasizes the primacy of formal federal guidance, particularly OMB Circular A-21. It addresses key technical topics such as depreciation methodologies, interest treatment, utility cost allocation, the exclusion of federally funded equipment, handling of capital assets, and space documentation, highlighting frequent areas of interpretive divergence between institutions and the DCA.
COGR’s interpretations are presented to clarify instances where the DCA’s guidance may be overly prescriptive or inconsistent with established policies and operational realities. The organization advocates for flexibility, urging institutions to develop transparent, well-documented costing methodologies tailored to their unique circumstances and to maintain open communication with federal negotiators. Specific issues include the allocation of library costs (with allowances for specialized libraries and differential treatment of outside users), the complexities of the Direct Charge Equivalent (DCE) methodology for departmental administration, and the need for practical approaches to facility cost projections—each requiring contextual solutions that may differ from uniform federal interpretations.
Throughout the report, COGR calls for the use of the DCA Manual as an interpretive tool rather than binding regulation, arguing for negotiations grounded in sound, defensible institutional practices. The document encourages institutions to seek professional guidance as needed and to strive for equitable F&A rates through collaborative, transparent negotiations. Ultimately, the manual serves both as a resource for understanding federal expectations and a guide for fostering pragmatic, mutually beneficial solutions in the administration of research-related costs.
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