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Policy No.: 6100
Effective Date: 06/27/02
Revised Date: 11/21/17
Reviewed Date: 11/21/17

Sponsored Programs Costing Policy
Treatment of Direct, Facilities and Administrative, and Unallowable Costs on Sponsored Programs

Basis of the Policy

It is the policy of the University of Nebraska Medical Center (UNMC) to comply with federal regulations applicable to externally funded projects. According to Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (“Uniform Guidance”) 2 CFR 200:

• Direct costs should be necessary for the project, reasonable, consistently treated with similar costs in like circumstance, and documented
• Costs that cannot be specifically identified with a particular project should be treated as Facilities and Administrative costs
• Some costs are not reimbursable under the terms and conditions of an award

Purpose of the Policy

To establish guidelines for identification and treatment of:

• Allowable Direct costs
• Facilities and Administrative costs
• Unallowable costs

Definitions

Uniform Guidance §200.403 provides the following general criteria for costs to be allowable on a federal award:
a) Be necessary, reasonable, and allocable
b) Conform to applicable cost principles
c) Be consistent with policies and procedures that apply uniformly to both federal and non-federal awards
d) Be accorded consistent treatment
e) Be determined in accordance with generally accepted accounting principles (GAAP)
f) Not be included on another award, as either a cost or to meet a cost-share requirements
g) Adequately documented

Uniform Guidance §200.413 provides the following general criteria for costs to be allowable on a federal award:
states that direct costs should be able to be identified specifically for a particular project relatively easily with a high degree of accuracy.

Uniform Guidance §200.414 states that Facilities and Administrative (“F&A”) costs, also known as indirect costs, are comprised of:

• Depreciation on buildings, equipment, and capital improvement; interest on debt associated with certain buildings, equipment, and capital improvements; and operations and maintenance expenses
• General administration and general expenses such as the director's office, accounting, and personnel and all other types of expenditures not listed specifically under the Facilities category

Unallowable costs are defined as expenses that are not reimbursable under the terms and conditions of a sponsored agreement and cost principles for allowability stated above. When a conflict arises between the sponsored agreement, cost principles and specific federal guidance, the agreement prevails. Federal projects must meet requirements listed specifically identified as unallowable in Uniform Guidance 2 CFR 200.

Policy

The Principal Investigator is responsible for managing his/her project in compliance with the terms and conditions of the award.

It is the policy of UNMC to comply with Uniform Guidance’s General Provisions for Selected Items of Cost §200.420 through §200.475, as well as the National Institutes of Health’s (NIH) Grants Policy Statement on Selected Items of Costs §7.9.1 for federally and NIH sponsored programs.

It is also the policy of UNMC to account for Facilities and Administrative costs in accordance with Appendix III to Uniform Guidance (“Indirect [F&A] Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education [IHEs]”).

The salaries of administrative and clerical staff should normally be treated as F&A costs. Direct charging may be appropriate only if:

• Administrative or clerical services are integral to the project
• Administrative or clerical staff can be specifically identified with the project;
• Such costs are explicitly included in the budget or have the prior written approval of the sponsor; and
• The costs are not also recovered as indirect costs

If a cost benefits two or more projects in proportions that cannot be determined either without undue effort or because of the interrelationship of the projects, then the cost may be allocated to the projects based on the proportional benefit or a reasonable documented basis.

UNMC prohibits the following practices for all sponsored projects because they do not conform with allowability cost principles:

• Charging costs based on the budgeted amount rather than on the actual expenses incurred
• Assigning costs in advance of when costs are incurred
• Changing the description of costs
• Assigning costs to grants based on available funds
• Transferring costs among and between grants without adequate cause
• Charging cost overruns from one grant to another

Certain unallowable costs are specific to some projects and programs. Treatment and application of circumstantial unallowable costs are determined by:

• Specific Sponsor Limitations (such as the NIH Grants Policy Statement or Uniform Guidance 2 CFR 200)
• Indirect Cost Rate
• Terms and conditions of the award

Additional Information

• Any questions about this policy should be referred to Financial Compliance and Cost Analysis
• UNMC Procedure No. 6100, Sponsored Programs Costing
• Sponsored Programs Administration F&A Rates Policy
• F&A Cost Waiver Request Form
• “Uniform Guidance” 2 CFR 200
• Appendix III, Uniform Guidance “Indirect [F&A] Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education [IHEs]”

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