If the Budget Activity (BA) 6 costs are budgeted for DoD laboratories to support critical infrastructure and associated personnel costs, would it be allowable to use funds from BA6 for the cost of laboratory personnel? Specifically, would the costs be allowable if the personnel were not associated with any specific research project but supported all (or potentially all) activities at the lab? For example, would the cost of personnel, such as travel agent, librarian, human resource director, budget and plans office, or other personnel who are not research scientists or technicians be allowable?
Based on my interpretation of the language in the paragraph of FMR you cited, I would say that personnel costs are limited to BA one, two or three. Here is the FMR paragraph you referenced:
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Budget Activity 6, RDT&E Management Support. This budget activity includes research, development, test and evaluation efforts and funds to sustain and/or modernize the installations or operations required for general research, development, test and evaluation. Test ranges, military construction, maintenance support of laboratories, operation and maintenance of test aircraft and ships, and studies and analyses in support of the RDT&E program are funded in this budget activity. Costs of laboratory personnel, either in-house or contractor operated, would be assigned to appropriate projects or as a line item in the Basic Research, Applied Research, or Advanced Technology Development program areas, as appropriate.
The last line of the paragraph above says” Costs of laboratory personnel, either in-house or contractor operated, would be assigned to appropriate projects or as a line item in the Basic Research (BA1), Applied Research (BA2), or Advanced Technology Development (BA3) program areas, as appropriate”
In my research, I can tell you that at least one service (Air Force) does not use BA06 for any laboratory costs. Personnel and support costs are budgeted and captured as full costing in the 24 S&T PEs BA01-BA03 where the work they support is accomplished.
If you meant BPAC06- the management BPAC, again the AF does not use the BPAC06 account either since the 1996 POM. This was part of the full cost initiative where everything is budgeted fully will the individual S&T workload it supports (full costing). As you know, often services have their unique polices; so please check with your Army FM authorities.