To charge or not to charge, that is the question:
Whether ’tis nobler in the mind to suffer
The slings and arrows of outrageous expense,
Or to take arms against a sea of regulations
And by opposing, end them

Almost certainly the OMB doesn’t consider the dilemma it places researchers in akin to Shakespeare’s Hamlet, but then the OMB bureaucrats are not researchers or research administrators. The dilemma is real and probably won’t get easier for us now with huge government deficits that will probably impact almost all Federal agencies and by trickle-down, affect us.

the government views computers in almost all cases as general purpose equipment. And the government employees most apt to review our costs, the dreaded auditors, all realize how general purpose computers are. Almost all auditors nowadays have a laptop they take with them to the field. They use it for e-mails, they use it for internet research, and I’m sure they send jokes and birthday cards to each other. they understand the general nature of the computer. to convince them that we are using our computers (laptop or desktop) only for research purposes is a very hard sell. It isn’t impossible, but it is definitely getting rarer.

In order to justify a computer for charging to a Federal program, you need to clear a number of hurdles. First, the cost must benefit the award and be reasonable and necessary such that a prudent person could conclude it is an appropriate cost. Just because the investigator doesn’t have other funding and he or she needs a computer to do some of the analytic work doesn’t justify the expense to the award. This is the lowest of the hurdles and one most investigators concentrate on, but the other two are just as important.

Second, the cost must be allocable to the award. This usually means that the computer is going to be used exclusively on the program, or if it is to be shared with another program, that the multiple usages can easily be documented using reasonable methods that approximate the benefits received by the multiple users. Arbitrary percentages of use are not acceptable. Being allocable is almost impossible to document if the computer is connected to the internet or available to a number of users since there are so many possible uses that can’t be prevented or documented. Even a desktop in a Biosafety Level 4 (highest) lab, if connected to the internet, could be used for many non-program tasks. Indeed, you might expect it would be used for non-program tasks so the people in the lab wouldn’t have to leave the lab and get out of their hazard suits just to use the internet for personal or non-program uses.

Third, the computer must be consumed by the program. A good example would be a computer purchased with a five year life that is bought in the first years of a ten year project. On the other hand, if the computer has a life of five years and the program was only for one, the program would have been charged with five years expense for one year of use. This is neither reasonable, nor is the cost allocated equitably. In addition, there is the issue of the use of the computer after the program ends. If, for example, the computer is used for departmental purposes, we have an inconsistency. the computer was initially charged as a direct cost but for 80% of its life it is being used to support the department, not the program. This is a violation of the consistency in costing principle. One way to avoid that issue is to sell the computer at a fair market value at the end of the year and credit the proceeds to the program. This isn’t very practical nor is it easy to monitor.

So what are we to do? “To sleep, perchance to dream – ay, there’s the rub.”

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