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Food/Meals

GCA no longer applies the food flag to sponsored award budgets. Departments are responsible for knowing if food for a particular event was included in the proposal or that written sponsor approval has been obtained. The food approval form is not required for sponsored awards. For more information, see PAFC's web page on Food Purchases on Sponsored Awards.

This depends on the sponsor and the terms and conditions applicable to the award. Some sponsors do not allow meal costs for employees of the institution if they are not in travel status. If they are attending the workshop and the sponsor has approved paying for their meals, the sponsor's written approval should be retained on file.

The cost of the dinner and how it benefits the Award should be part of the original proposal and budget. As with all expenses, there is a requirement to show how the expense is necessary for the achievement of the award objectives. See PAFC's web page on Food Purchases on Sponsored Awards for more information.

In planning a meeting/conference, ensure that the vendor will itemize food purchases separately from other costs. If the vendor embeds food and beverage costs into the total cost of the meeting space, the department should work with the vendor to have the food and beverage costs identified separately. Refer to PAFC's web page Food Purchases on Sponsored Awards for more information.

The food and beverage cost, including any applicable taxes, tips, and service charges, may not exceed the per diem allocation for the meal. Some non-federal sponsors may allow meal costs to exceed the standard per diem rate. Written sponsor approval is required in these instances. 

Auditors scrutinize meal purchases because they can include unallowable costs such as alcohol and/or per meal costs over the per diem allocation. Provision of an itemized receipt will provide proof of the cost allowability.

Gifts/Donations/Discretionary Budgets

Information on discretionary budgets can be found on GCA's Discretionary Budgets web page. According to the Operating Policy Used to Administer Discretionary Fund Budgets referenced by GCA, salaries and benefits are allowed on discretionary funds.

Generally, accepting gifts from suppliers/vendors could be construed as creating a conflict of interest. For more information, see UW Internal Audit's ethics page.

The value (cost) of the unused gift cards should be refunded to the sponsored award, since the gift cards were not used. The cost should be transferred to a non-sponsored award budget. The gift cards may then be used in accordance with the requirements of the funding source the cost of the gift cards was transferred to. For example, if the cost of the gift cards was transferred to a department budget, the gift cards should be used in accordance with the requirements or guidelines of the department budget.

This type of expense is not allowable. According to CFR 200.434 Contributions and donations: Costs of contributions and donations, including cash, property, and services, from the non-Federal entity to other entities, are unallowable.

It is the expectation that these funds are for the benefit of the University, rather than the individual PI. The Dean/Director/Chair has the authority to direct the use of the funds at the request of an individual PI.

Intellectual Property

Assuming this a federal grant, 2 CFR 200.448 Intellectual Property, which covers the allowability of patent costs, applies. The regulation does not makes a distinction for provisional patents, so the regulation would apply. If title to the patent or a royalty-free license is required to be conveyed to the federal government, the cost would be allowable when a provisional patent is required in order to secure the final patent. If title or royalty-free license is not required by the federal award, then the cost would not be allowable.

Memberships/Subscriptions

As the benefit of this membership can be received by any number of Awards, the cost cannot be allocated to a single Award. The cost of membership should be billed to either department funds or a discretionary budget.

Federal regulations allow the cost of the institution's membership in business, technical, and professional organizations as part of F&A, but do not mention individual memberships. Per GIM 23, individual memberships are allowable only as an indirect cost. This is because professional memberships benefit the individual in all of their professional work; the cost cannot benefit just a single Award. Thus, the cost cannot be included on an Award budget.

As the nature of a membership in one of these organizations provides a benefit to all the work and professional activities of the individual, it is difficult to allocate the cost of this benefit to a single Award. For this reason, individual memberships are not allowable as a direct cost on an Award.

Institutional subscriptions may be allowable when directly related to the objectives of a sponsored Award. An example of an allowable direct charge of an institutional subscription would be where the Award objective is to compile data from articles into a database, or if the subscriptions are needed as reference material to support the Award.

Per GIM 23, individual memberships and subscriptions are allowable only as an indirect cost. This is because professional memberships and subscriptions benefit the individual in all of their professional work; the cost cannot benefit just a single Award. Thus, the cost cannot be included on an Award budget.

No Cost Extension

Federal agencies have different requirements. Some agencies may require the same level of effort as was proposed during the original term of the award, but others will not. For instance, NIH currently only requires a “measurable” level of effort for the PI and other key personnel during the term of the award, including any NCE periods. NSF takes a different view and assumes that the originally proposed effort will be spread over the entire award period, including any NCE periods. As a best practice, we recommend following sponsor specific terms and conditions, which may include FAQs. 

In the absence of guidance from the sponsor, if committed faculty effort will be reduced 25% or more during the extension period, a request for approval to reduce faculty effort should be submitted to the sponsor at the same time as the NCE request or notification. If no mention is made of faculty effort reduction during the NCE, then there is an expectation that the effort remains at the same level as committed during the original award period.

Project End Dates

This is a question of allocability. Does the contract provide a direct benefit to the sponsored award over the entire life of the contract? For contracts that extend beyond the end date of an award, the cost should be allocated on a reasonable basis. Typically that basis is the number of months the award is active during the life of the contract. Once the award ends, the contract is no longer providing a benefit to the award, so that portion of the contract cost is not allocable to the award.

Proposal Costs

The costs of preparing bids, proposals, or applications for the receipt of any new funding are generally unallowable as direct costs on existing awards. This includes proposal costs for a new award, a competing segment of an existing program, or for supplemental funding on an existing award.

The reason that proposal costs are unallowable is because any costs charged to an Award must provide benefit to that Award. It is difficult to justify how the expenditure of effort for new funding is of benefit to the existing Award. How does effort spent on obtaining additional funding provide benefit to the objectives of the existing award?

Costs related to the receipt of funding for a non-competing segment of an existing award are allowable. This is because these funds are not considered new funding since they are identified in the award.

Also, under NIH Mentored Career Development (CDA or mentored “K”) awards, it is allowable for effort devoted to proposal preparation for subsequent research support to be direct charged. This activity can be considered part of the awarded effort commitment.

Publication Costs

2 CFR 200.461 states that “publication costs,” including “costs for electronic and print media, including distribution, promotion, and general handling" are allowable as a direct cost when identifiable with a particular award.  

Page charges for professional journal publications are also allowable when:

—The publication reports on the work supported by the award, and
—The publisher charges the same costs for all items published. 

These costs may be incurred after the end date of the award (Total Period End Date), but before award closeout. This means that the costs must be posted to the award (paid) by the Final Action Date (FAD) in order for the costs to be included in final invoicing/reporting. If it is anticipated that publication costs will need to be paid after the FAD, then a No-Cost Extension (NCE) must be obtained or requested from the federal sponsor.

As with any type of cost, an estimated amount of anticipated publication costs may not be added to the final invoice/financial report to allow for costs to be incurred after the FAD.  

Report Costs

Grant writing and reporting costs that are required as part of the terms of the Award are allowable. For example, progress reports, annual reports, and/or technical reports are required and therefore, would be allowable. Proposal costs, however, would not be an allowable expense. See the FAQ on Proposal Costs.

Return Costs

It depends on the reason for the return. If the item was purchased in error, then any costs related to the return are unallowable, as the reason for the return is due to error on the part of the purchaser and is thus not an allocable cost to the Award. If the reason for the return is due to directive from the Sponsor or due to a change in the scope or implementation of the Award, then the return costs may be allowable.

Room Rentals

If it is for research or study space, it probably would not be allowable because that space is included in our F&A rates. If it is meeting space “owned” by an auxiliary enterprise such as student housing, the HUB, or athletics, the room rental fee might be allowable. We would need to determine if the space is included in the F&A rates or not.

UW-owned facilities that are used for instruction, research, or administration would be included in the F&A rates and therefore a rental or fee charged for the use of those facilities would not be allowed as a direct cost. Facilities that are set up for recharge or as a cost center are an exception, as these are identified and removed from the facilities component of the F&A rates. In addition, facilities operated by auxiliary groups such as student housing, athletics, the HUB, and the cultural center are not included in the F&A rates, so charges for use of those facilities would generally be deemed allowable.

Just because it is in the proposal and funded does not make it allowable. The prohibition against double charging would take precedence over inclusion in the proposal.

Salary Cap

Guidance from NIH can be found on NIH's website under the section "Guidance on Salary Limitation for Grants and Cooperative Agreements" for the current fiscal year. NIH's salary cap summary dating back to FY1990 is another helpful resource.

Stipends

"Stipend" is a troubling term, as different entities and individuals use it in different contexts. For most federal sponsors, a stipend represents a fixed amount provided to someone in a training program to offset their living expenses. It is not remuneration or compensation provided for work performed; therefore, the payment does not represent FTE or effort. Some non-federal sponsors will use the term synonymously with compensation for work performed.

So, in this case, a stipend would not be allowable, but salary or wages (compensation) would be allowable.