| Grants and Contracts: Post- Award
Administration
The following
topics describe unallowable costs, definitions, examples/ explanations
to help researchers manage federal grants and cooperative agreements,
as well as contracts. The post-award staff provide projections
of costs, prepare budgets and budget changes, prepare salary plans,
oversee grant regulations, prepare financial reports, and act as
your liaison to central administration.
Transferring/Charging Expenditures
Appropriately
(journal vouchers or other transfers)
Transfers from
one federal project to another
federal project are not allowable unless the projects are related
as to scope of research and must be justified when requested
. It does not include non-competing continuations and renewals
when
the agency/sponsor grant number does not change. Transfers
from general funds or other miscellaneous funds must include detailed
and reasonable explanation as to why charges were
not initially placed against the inappropriate account. If
charges were directly billed or placed through standing orders,
explanations are required documenting the necessity of not charging
the appropriate grant initially. To avoid unnecessary transfers
(on proposals not yet awarded), an investigator should request
an Advanced Fund Number.
Advanced Fund Number
If the award
has not been received from the sponsor and a fund number has not
yet been established,
an Advanced Fund Number can be requested through the College's
Grants and Contracts Office in 201 Henderson. The department/center
must feel confident that the project will be funded and be effective
for the date that the investigator has indicated. If the proposed
project is not effective for the particular time that charges were
incurred or it is not funded, the department/center would be responsible
for all costs that were incurred. If you have had the practice
in the past of charging general funds because a grant has not yet
been funded and then later charging the grant by journal voucher,
this would eliminate the duplication of paperwork.
Factors
for Charging Grants Appropriately
- Placing expenditures must be
given consistent treatment through application of generally accepted
accounting principles and appropriate
to the circumstances.
- Always provide a detailed description of
the purchase/charge. This
provides approvers and auditors reasonable information needed
to determine if charge is allowable (grant related).
- Expenses
should be considered a necessity to operate the research in
a prudent and efficient manner and be reasonable and allocable
under cost principles.
Budget Categories and Stipulations
For ALL Miscellaneous
Funds refer to specific sponsor requirements and regulations
Postage : Is it daily or bulk mailing? Daily postage
is not allowable. Shipping charges are only allowable if
directly related with the research project. Surveys/bulk
mailings are allowable. Postage should be described on the proposal
budget to assure allowability.
Telephone : (long-distance) Dedicated
phone lines should be established for use on the project. If
not, researchers must log all appropriate calls in relation to
the project to include purpose,
contact name and date (this would include faxes). This is necessary
documentation required if audited, and could be required for approval
of a transfer request.
Telephone equipment rental/installation
charges: In order for these types of charges to be allowable,
FEDERAL guidelines indicate that they should be listed in the proposal
budget as integral to the operation of research. Budgets for which
charges are placed and do not have prior approval, will require
justification on file and are susceptible to disallowance. Standing
Orders : If a standing order is used to purchase
expenditures on miscellaneous funds, generally it should only be
used for emergency purposes. Unless a project has unusual
specific ordering requirements, individual orders should be placed
to allow verification and allowability of the purchase.
Visa Card
Purchases : These charges must be reconciled against
the appropriate account at the time of resolution. If reconciled
incorrectly, an appropriate explanation must be included with the
request to transfer.
Salary & Wage Transfers : If requesting
a transfer over 30 days on federally funded projects, a written
justification is
required explaining the unusual circumstances *which delayed the
appropriate charge to be made within 30 days.
*Due to the University effort verification system,
reasonable explanations for exceptions over 30 days must be valid,
accurate and include
documentation.
Example :Joan thinks it would be nice
to have music playing while her researchers conduct experiments
in the laboratory because it
would enhance their performance. Joan wants to purchase a CD player
and CD's. Allowable, NO! Example :Joan would like to purchase t-shirts
for all of her research staff with a logo in reference to their
research. Allowable, NO! Example: Joan wants to take her
research group to lunch and talk about the project and then request
it be charged against the project. Allowable, NO!
SABBATICAL
LEAVE COSTS: Costs/salary while on leave of absence are allowable
provided the University has a consistent policy for
persons engaged in research or instruction. Please Call your Human
Resource Rep for salary information and Val Patrick of the Research
Office in regard to effort charged to the Research budget.
According to University Policy on the regulations regarding use
of support funds and receiving outside compensation during sabbatical
leaves of absence, " A Faculty Member may Augment the Sabbatical
Leave Stipend (67%) with funds from a Grant or Contract if APPROVED
by Both the Dean (or the Senior Vice President for Research and
Dean of the Grad School) and with Written Approval from the Granting
Agency . In No Case Shall the Total Exceed the Amount of
a Normal Full Salary of the Individual for the Period of Leave." For
more information, please see: http://guru.sp.psu.edu/POLICIES/hrg15.cfm
FINES/TICKETS, PENALTIES: Not Allowable on Federal
Funds Unless Unusual circumstances are Involved.
Example: Researcher's were at an expected launching of a shuttle
and due to inclement weather the launching was delayed; grant personnel
associated with the launching had to change their air flight arrangements
and were penalized by the airline. This Would Be Allowable. In
other words, fines and penalties out of your control, could be
allowable dependent upon the situation. Instances must be considered
on a case to case basis.
TRAINEE GRANTS: Trainee expenses can not be re-budgeted
for other costs, but "other costs" budget categories
can be re-budgeted into trainee expenses. In other words, tuition/fees
and stipends
cannot be re-budgeted. Also, these charges are not charged indirect
costs. Department/Centers are responsible for managing the
allowable per trainee costs and must not exceed the designated
amounts without approval. Justification would be required
in case of an audit. For more information, see the following
website: http://www.nih.gov/grants/guide/notice-files/not98-161.html
EQUIPMENT
EQUIPMENT: An article of non-expendable
tangible personal property having a useful life of more than 2
years and an acquisition
cost of $500 or more per unit. Capital Equipment: Unit cost of
$5,000 or more.
Equipment SHOULD NOT be purchased in the FINAL (6) months of a
federally funded project. A reasonable justification will
be required.
EQUIPMENT including FABRICATION: Expenditures
for general purpose equipment which would be treated as direct
costs for the project/program
are unallowable, unless the equipment is primarily used in the
actual conduct of the research. For any item with an acquisition
cost of $5,000 or more, the Federal Government may request that
the title be transferred.(Refer to FDP1996)
General Purpose Equipment:
Equipment, the use of which is not limited to "special purpose".
Examples of general purpose equipment are: office equipment/furnishing,
printing/copying, motor vehicle,
automatic data processing and air conditioning. NOT allowable
on federal funds without prior approval.
Special Purpose Equipment:
Equipment that is used only for research, medical, scientific,
or other technical activities.
Maintenance expenses and replacement parts are not classified as
equipment. System software when ordered in conjunction with a new
piece of equipment can be considered part of the equipment (coded
and capitalized accordingly). An independent software package such
as word processing or spreadsheet software is subject to the University's
indirect costs and coded as software. Equipment on Conference
Grants must be rented and necessary. Equipment may not be purchased.
Fabrication of Equipment: (Check GURU for updates
on policy.) The
materials and other associated costs in the construction of a piece
of CAPITAL equipment. Permission must be received from the Property
Inventory Department to code orders fabrication (code 705) and
the approved copy must be sent to the Financial Office. After construction,
Property Inventory must be notified. The item then will be inspected
and evaluated for compliance with the University's definition of
capital equipment and tagged. If construction has taken place and
orders were not coded fabrication, the department must provide
a log of all costs and sources of funding in the construction.
A summary of associated labor costs to be capitalized is also required.
(Property Inventory will inspect the equipment and then prepare
the journal entry to capitalize the items).
Conditions of Travel
Arrangements Charged to a Federally Sponsored Project: It
is NOT allowable when an employee makes travel arrangements and
is aware that the travel will be reimbursed from
another source or that he/she will be reimbursing the budget for
a trip that is not grant related . Grant funds should not be used
and would be subject to audit.
FOREIGN TRAVEL: Federal grants
or Cooperative Agreements no longer require prior approval, but
still have specific regulations. The
traveler must use a US Flag carrier unless proof that such a carrier
is not available or agency approval is obtained in writing. Cost,
convenience, and/or Personal Preference is not an acceptable justification
for use of a foreign carrier (FDP1996)
Travel Reimbursement (Federal
Grants): The individual seeking
reimbursement must be working on the project which is generally
evidenced by his/her effort being charged/paid by the project. This
may not apply to a Principal Investigator or non-university personnel
performing duties directly associated with the grant but contributing
their time to a project. Under no circumstances can an individual
receive travel support from one project and be paid 100% effort
from another project. Teaching assistants who are spending
a portion of their effort toward a particular project may also
charge travel support.
Group Meeting Expenses or Group Meals
(Federal Funds): PSU
employees, Individual and Groups are only allowable if on travel
status. There is no such thing as a working lunch or business
meeting . Example: Expenses of investigators/project
directors or other employees who are not on travel status , serving
as hosts, including interviewing prospective candidates, or otherwise
participating at meals that are primarily social occasions involving
speakers or consultants are not allowable . The cost of the
consultant/speaker meal is allowable or any Non-PSU employee or
federal employee.
Entertainment, amusement, diversion, and social
activities and any costs directly associated with such costs
(such as tickets
to shows or sporting events, meals, lodging, rentals, transportation,
and gratuities) are unallowable. |