Exceptional Circumstances

GuidelinesBack to Top

  • Costs charged to sponsored projects must be allowable as specified in OMB Circular A-21: Cost Principles for Educational Institutions (for federal projects) or per sponsor agreement terms (for non-federal projects).
  • Costs must be consistently treated, i.e., if a cost is treated as F&A for most projects, it cannot be charged as a direct cost on a given project. For example, charges such as memberships, subscriptions, and computer costs typically cannot be treated as direct costs.
  • A cost normally treated as F&A may be eligible for treatment as a direct cost under Exceptional Circumstances. Exceptional Circumstances are determined on a case by case basis and must have prior approval via an Exceptional Circumstance Request.


Costs are reimbursable by the Federal Government ONLY if they are:

Necessary, Reasonable, Allocable, Allowable, Consistently Treated, and Permissible

Find out more about Cost Principles in our FAQ section.

Exceptional Circumstance Request ProcessBack to Top

Requests for exceptional circumstance approval must be made in writing IN ADVANCE OF THE PURCHASE. A request form can be downloaded from the Research and Sponsored Programs Office.

Please include full justification to why to the item(s) is required and why a CAS exception would be appropriate. This justification must explain how it specifically benefits the project(s) it is being charged to.

The request may be routed either in hardcopy or via email. Send the request to your departmental CALS Business Services Contact.  The Dean’s Office will review and if acceptable, forward to RSP.

ResourcesBack to Top

These references may help you in determining if costs are allowable or unallowable.

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