Research Indirect Cost Policy

Memo: Establishing ACLU-KY Research Indirect Cost Policy
Effective July 12, 2021
Prepared by Amber Duke

As the ACLU of Kentucky refines its strategies for tackling critical problems in the commonwealth, the advocacy director has identified research as a key tool for helping us win and evaluating the impact of our work. To be good stewards of our resources, we are establishing a Research Indirect Cost Policy. Any questions about this policy can be directed to ACLU-KY Deputy Director Amber Duke.

ACLU of Kentucky
Research Indirect Cost Policy

The ACLU of Kentucky (ACLU-KY) occasionally engages in research to advance civil liberties and civil rights or measure the impact of our policy and legal work in the commonwealth. To do this, ACLU-KY may partner with others, identified as “Contractors,” to coordinate and/or conduct this research.

One cost consideration is Indirect Cost (may be referred to as “Overhead”), also known and defined by the federal government as Facilities and Administration (F&A). Indirect/F&A Costs may include an allocation of the Contractor’s rent, utilities, equipment, information systems, administrative support, etc., that are not directly and completely attributable to the research.

To ensure that most of our funds directed toward research are used to support research activities, ACLU-KY limits Indirect/F&A Costs to no more than 10% of the total direct costs. ACLU-KY will not pay for a charge for indirect costs that are typically included as direct costs. A Contractor with actual indirect costs lower than 10% should not charge an amount in excess of actual indirect costs. The intent is to sufficiently fund actual costs, not to generate financial surpluses for the Contractor. ACLU-KY reserves the right to request substantiation of any Contractor’s Indirect Cost rate.