Difference between revisions of "Sponsored Programs Costing"

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<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF"  
 
width="20">[[Intellectual Property]]</td>
 
width="20">[[Intellectual Property]]</td>
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<td style="border-bottom:2px solid #A3B1BF" width="3">&#160;</td>
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<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF"
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width="20">[[Faculty]]</td>
 
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<br />
 
<br />
[[Sponsored Programs]] | [[Direct Cost]] | [[Facilities & Administrative Cost]] | [[Institutional Base Salary]] | [[Unallowable Cost Policy]] | [[Sponsored Project Cost Share]] | [[Effort Certification]] | [[Cost Transfer]] | [[Service Center]] | [[Subrecipient Policy]]
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[[Sponsored Programs]] | [[Sponsored Programs Costing]] | [[Institutional Base Salary]] | [[Sponsored Project Cost Share]] | [[Effort Certification]] | [[Cost Transfer]] | [[Service Center]] | [[Subrecipient Policy]] | [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]
 
<br /><br />
 
<br /><br />
  
 
Policy No.: '''6100'''<br />
 
Policy No.: '''6100'''<br />
 
Effective Date: '''06/27/02'''<br />  
 
Effective Date: '''06/27/02'''<br />  
Revised Date: '''05/07/07'''<br />
+
Revised Date: '''11/21/17'''<br />
Reviewed Date: '''05/07/07'''<br />
+
Reviewed Date: '''08/11/22'''
  
 
<br />
 
<br />
<big>'''Direct Cost Policy'''</big>
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<big>'''Sponsored Programs Costing Policy<br />
 +
Treatment of Direct, Facilities and Administrative, and Unallowable Costs on Sponsored Programs'''</big><br />
 +
 
 
==Basis of the Policy ==
 
==Basis of the Policy ==
It is the policy of the University of Nebraska Medical Center (UNMC) to comply with the federal government’s regulations for funding of projects from external sources, including the federal government. These regulations state that direct costs must be reasonable, allocable, allowable and treated consistently in the budgeting and the actual expending of the direct cost.
+
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”) [https://www.ecfr.gov/cgi-bin/text-idx?SID=0d3801e083204d6d1c56e6b465e95e09&mc=true&node=pt2.1.200&rgn=div5#se2.1.200_1413 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 ==
 
== Purpose of the Policy ==
To establish guidelines surrounding the definition of direct costs.
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To establish guidelines for identification and treatment of:
 +
*Allowable Direct costs
 +
*Facilities and Administrative costs
 +
*Unallowable costs
 
== Definitions ==
 
== Definitions ==
Direct costs are those that can be specifically identified with a particular sponsored project or activity and can be assigned to that project or activity with a high degree of accuracy. In order for a direct cost to be allowable cost to a sponsored program, it must meet three criteria:  
+
Uniform Guidance [https://www.ecfr.gov/cgi-bin/text-idx?SID=4f64d0f8f4a60493ef6b04a1737480ff&mc=true&node=se2.1.200_1403&rgn=div8 §200.403] provides the following general criteria for costs to be allowable on a federal award:<br />
*Reasonable - It must be necessary for the performance of the program
+
a)  Be necessary, reasonable, and allocable<br />
*Allocable - It must be easily identifiable with the project and be assigned to the project only in accordance with the benefits received by the program
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b)  Conform to applicable cost principles<br />
*Allowable - Costs that are reasonable; allocable to sponsored agreements under the principles and methods outlined in [http://www.whitehouse.gov/omb/circulars OMB Circular A-21]; given consistent treatment thorough application of those generally accepted accounting principles appropriate to the circumstances; conform to any limitations or exclusions set forth in OMB Circular A-21 or in the sponsored agreement as to types or amounts of cost items.
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c)  Be consistent with policies and procedures that apply uniformly to both federal and non-federal awards<br />
Consistently Applied - The cost must be treated consistently as either a direct cost or a facilities & administrative (F&A) cost when incurred under like circumstances.  
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d)  Be accorded consistent treatment<br />
 +
e)  Be determined in accordance with generally accepted accounting principles (GAAP)<br />
 +
f)  Not be included on another award, as either a cost or to meet a cost-share requirements<br />
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g) Adequately documented<br />
 +
 
 +
Uniform Guidance [https://www.ecfr.gov/cgi-bin/text-idx?SID=0d3801e083204d6d1c56e6b465e95e09&mc=true&node=pt2.1.200&rgn=div5#se2.1.200_1413 §200.413] provides the following general criteria for costs to be allowable on a federal award:<br /> 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 [https://www.ecfr.gov/cgi-bin/text-idx?SID=0d3801e083204d6d1c56e6b465e95e09&mc=true&node=pt2.1.200&rgn=div5#se2.1.200_1414 §200.414] states that Facilities and Administrative (“F&A”) costs, also known as indirect costs, are comprised of:<br />
 +
*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 ==
 
==Policy ==
It is the policy of the University of Nebraska Medical Center (UNMC) to comply with Section D of OMB Circular A-21 in its definition and treatment of direct costs. It is UNMC's policy to treat the following costs as direct costs in the administration of its extramural programs:
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The Principal Investigator is responsible for managing his/her project in compliance with the terms and conditions of the award.<br />
*Salaries of principal investigators, research assistants, postdoctoral research associates, research associates, and technical staff
+
 
*Fringe benefit costs associated with the salaries of directly charged personnel
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It is the policy of UNMC to comply with Uniform Guidance’s General Provisions for Selected Items of Cost [https://www.ecfr.gov/cgi-bin/text-idx?SID=f58b601f76edc779c355c76d49c39526&mc=true&node=sg2.1.200_1419.sg16&rgn=div7 §200.420 through §200.475], as well as the National Institutes of Health’s (NIH) Grants Policy Statement on Selected Items of Costs [https://grants.nih.gov/grants/policy/nihgps/HTML5/section_7/7.9_allowability_of_costs_activities.htm#Selected §7.9.1] for federally and NIH sponsored programs.<br />
*Animal per diems
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*Other specialized services
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It is also the policy of UNMC to account for Facilities and Administrative costs in accordance with [https://www.ecfr.gov/cgi-bin/text-idx?SID=f58b601f76edc779c355c76d49c39526&mc=true&node=pt2.1.200&rgn=div5#ap2.1.200_1521.iii Appendix III] to Uniform Guidance (“Indirect [F&A] Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education [IHEs]”).<br />
*Laboratory supplies including chemicals and glassware
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*Long distance telephone charges
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The salaries of administrative and clerical staff should normally be treated as F&A costs. Direct charging may be appropriate only if:
*Travel costs
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*Administrative or clerical services are integral to the project
*Rental charges for off campus facilities
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*Administrative or clerical staff can be specifically identified with the project;
*Equipment costing less than the capitalization threshold
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*Such costs are explicitly included in the budget or have the prior written approval of the sponsor; and
*Computer software and supplies
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*The costs are not also recovered as indirect costs
*Other supplies and tools required in the conduct of the sponsored program
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*Tuition remission for graduate research and teaching assistants
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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.<br />
*Consulting services
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*Sub contracted portions of the program
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UNMC prohibits the following practices for all sponsored projects because they do not conform with allowability cost principles:
Under certain circumstances, it may be appropriate to charge other costs, normally treated as F&A costs, directly to the program. These are representative of special circumstances, and, in order to be chargeable, must be specifically identified with a project or activity and approved by the awarding agency in the grant application or contract proposal. 
 
*Large complex research programs such as general clinical research centers (GCRC), cancer research centers, certain institutes, centers, and specific research activities funded by core grants
 
*Projects requiring extensive data collection, cataloging, data entry, surveys and tabulating questionnaires
 
*Product or reproduction of large reports, books, monographs
 
*Programs conducted in geographic locations which are not accessible to campus and campus administrative support
 
*Program project grants
 
It is the institutional policy to prohibit the following practices as they do not meet the requirements of the Circular governing acceptable assignment of costs:
 
 
*Charging costs based on the budgeted amount rather than on the actual expenses incurred
 
*Charging costs based on the budgeted amount rather than on the actual expenses incurred
 
*Assigning costs in advance of when costs are incurred
 
*Assigning costs in advance of when costs are incurred
 
*Changing the description of costs
 
*Changing the description of costs
*Charging costs incurred for joint purposes to a sponsored program
 
 
*Assigning costs to grants based on available funds
 
*Assigning costs to grants based on available funds
*Transferring costs among and between grants
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*Transferring costs among and between grants without adequate cause
 
*Charging cost overruns from one grant to another
 
*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 [https://www.ecfr.gov/cgi-bin/text-idx?SID=0d3801e083204d6d1c56e6b465e95e09&mc=true&node=pt2.1.200&rgn=div5#se2.1.200_1413 2 CFR 200])
 +
*Indirect Cost Rate
 +
*Terms and conditions of the award
 +
 
==Additional Information==
 
==Additional Information==
Any questions about this policy should be referred to [http://info.unmc.edu/dept/fincompliance/ Financial Compliance and Cost Analysis].
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*[mailto:mhrncirik@unmc.edu Senior Manager, Financial Compliance and Cost Analysis]
<br />
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*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]
[http://www.unmc.edu/spa/index.cfm?L1_ID=12&CONREF=119 UNMC Facilities and Administrative (F&A) Cost Waiver Request Policy and Procedure]<br />
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*[https://info.unmc.edu/management/finance/fincompliance/UNMC_6100_Grid.pdf UNMC Procedure No. 6100, Sponsored Programs Costing]
[http://webmedia.unmc.edu/spa/forms/FAWaiver.doc F&A Cost Waiver Request Form]
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*[https://www.unmc.edu/spa/grants/resources/idc-policy.html Sponsored Programs Administration F&A Rates Policy]
<br />
+
*[http://www.unmc.edu/spa/_documents/fawaiver.doc F&A Cost Waiver Request Form]
 +
*“Uniform Guidance” [https://www.ecfr.gov/cgi-bin/text-idx?SID=0d3801e083204d6d1c56e6b465e95e09&mc=true&node=pt2.1.200&rgn=div5#se2.1.200_1413 2 CFR 200]
 +
* [https://www.ecfr.gov/cgi-bin/text-idx?SID=f58b601f76edc779c355c76d49c39526&mc=true&node=pt2.1.200&rgn=div5#ap2.1.200_1521.iii Appendix III], Uniform Guidance “Indirect [F&A] Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education [IHEs]”
 
<br />
 
<br />
 
This page maintained by [mailto:dpanowic@unmc.edu dkp].
 
This page maintained by [mailto:dpanowic@unmc.edu dkp].

Latest revision as of 08:23, August 17, 2022

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Sponsored Programs | Sponsored Programs Costing | Institutional Base Salary | Sponsored Project Cost Share | Effort Certification | Cost Transfer | Service Center | Subrecipient Policy | On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects

Policy No.: 6100
Effective Date: 06/27/02
Revised Date: 11/21/17
Reviewed Date: 08/11/22


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


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