Policy 3.6.5.1

Policy and Procedures Manual

Classification Number: 3.6.5.1
Inception: March 9, 51³Ô¹ÏÍøÊÓƵ

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SUBJECT:  ALLOWABLE COSTS FOR FEDERAL GRANTS

 

Any costs charged to a federal grant needs to be reasonable and directly allocable to the supported activity as specified in the Uniform Guidance (2 CFR 200).

  • All costs incurred and allocated to federal grants must be reasonable and necessary to complete the proposed activities. Questions about costs should be discussed with the Vice President of Academic Affairs (VPAA), who may in turn consult with the Chief Financial Officer, before the expenditure is made. Principal Investigators (PIs) are not authorized to contract with outside agencies or vendors on behalf of the university.
    1. Reasonable means that a prudent person would have purchased the item and paid that price.
    2. Allocable means expenses are at least partially applicable to a sponsored agreement.
    3. Allowable means that the expense must be allowable or not specifically excluded as specified by government regulations (examples of specifically excluded costs are discussed later) or by the contract/grant/cooperative agreement requirements.
  • All expenditures from federal awards will be submitted to the VPAA for approval, including invoices, reimbursement requests, and stipend requests. Upon approval, the Office of the VPAA will forward the expense to the Business office for processing. Under no circumstances can a PI on an award directly charge expenses to an award. If an expense is inadvertently charged to an award without approval, the Business office is responsible for reversing the charge, and communicating the appropriate process to the PI.
  • Although some agencies permit grantees to incur allowable pre-award costs within the 90-day period immediately preceding the effective date of the grant, such expenditures are not permitted under 51³Ô¹ÏÍøÊÓƵ Baptist University (WBU) policy unless the cost is approved in writing by the Vice President of Academic Affairs (VPAA).
  • Grant funds may not be expended subsequent to the expiration date of the grant except to liquidate valid commitments that were made on or before the expiration date.
  • All remuneration paid currently or accrued by the organization for employees working on the grant supported project during the grant period is allowable to the extent that 1) total compensation to individual employees is reasonable for the work performed and conforms to the established policy of the organization consistently applied to both government and non-government activities; and 2) the charges for work performed directly under grants are determined and documented as provided in the applicable Federal cost principles.
  • Academic Year Salaries will be based on the individual faculty member's regular compensation for the continuous period which, under the policy of the institution concerned, constitutes the basis of his/her salary. In most cases, a faculty member's base salary is considered to be compensation for the 9-month academic year. Adjustments will be made as needed for faculty members on 10- or 12-month contracts.
  • During the summer months or other periods not included in the period for which the base salary is paid, salary is to be paid at a monthly rate not in excess of the base salary divided by the number of months in the period for which the base salary is paid. WBU will abide by federal policy on funding of summer salaries (known as two-ninths rule), regardless of the funding source, and no individual investigator will receive a summer stipend that exceeds two-ninths of the academic year salary. This limit includes summer salary received from all federal-funded grants.
  • Any payments to be made during a period of sabbatical leave must be approved in advance by the VPAA and explicitly specified in the grant award.
  • Expenditures for equipment are allowable only to the extent that they appear in the approved grant budget. Generally, expenditures for general purpose equipment (computers, etc.) are not allowed.
  • Expenses for transportation, lodging, subsistence, and related items incurred by project personnel and by outside consultants employed on the project who are on travel status on business related to a grant-supported project are allowable as prescribed in the governing cost principles and the WBU Travel Regulations Policy (policy 3.2.5). Travel funded under federal grants will additionally adhere to the following policies:
    1. Except as provided in the governing cost principles, the difference between economy airfare and a higher-class airfare is unallowable. A train, bus or other surface carrier may be used in lieu of or as a supplement to air travel at the lowest first-class rate by the transportation facility used. However, if such travel could have been performed by air, the allowance will not normally exceed that for jet economy airfare.
    2. Reimbursement for travel in a personal vehicle will be calculated at the current rate as specified in the WBU travel policy.
    3. Meeting and conference costs are only allowable if such costs are specifically and clearly identified in the proposed scope of work and budget, as modified and approved by the federal funding source. Grant funds are not otherwise to be spent for meals or coffee breaks for intramural meetings of an organization or any of its components, including, but not limited to, laboratories, departments and centers.
    4. Travel to foreign countries will abide by see GPM 761, " Note that US law requires that personnel travel on US Flag airlines whenever practicable.
  • Payment for consultant services should not exceed the amount shown in the award budget. Project personnel may request payment to consultants using existing WBU forms.
  • Participant support costs should not exceed the budgeted and approved amount and should follow the requirements described in the Participant Support Policy for Grants from Federal Agencies.
  • Cost associated with hosting conferences, symposia, workshops or other meetings supported by a federal grant must be specified in the budget and allowed by the agency and WBU. Any costs charged to a federal grant also need to be reasonable and directly allocable to the supported activity. Meeting and conference costs are only allowable if such costs are specifically and clearly identified in the proposed scope of work and award budget. Federal funds are not otherwise to be spent for meals or coffee breaks for intramural meetings of an organization or any of its components, including, but not limited to, laboratories, departments, and centers.

Contact for Interpretation:  Chief Financial Officer

This policy statement supersedes all previous policy statements on this subject.

 

Revisions:
03/09/51³Ô¹ÏÍøÊÓƵ – Inception

 

Printable Policy 3.6.5.1 Allowable Costs for Federal Grants

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