Please see the Cost Principles Policy Statement for additional information about the policy including sections with additional information on each FAQ set below.
Receipts or copies of receipts for all purchases (electronic copies are acceptable unless the sponsor has requirements for original receipts). Departments are responsible for ensuring receipts or copies of receipts are stored in accordance with CU Boulder records retention policies, generally with the department, in Concur, in CU Marketplace, or with another university-approved system. Receipts for purchases do not guarantee that the purchase will be considered allocable, allowable, and reasonable. Additional justification may be required if reasonableness is not self-evident.
No, per the Uniform Guidance Limitation on Allowance of Costs, this would not be allowable. Since the 10% effort was entirely allocated to the NIH grant, it cannot also be charged to another sponsored project.
The department is not responsible for ensuring this process is followed. The Campus Controller’s Office (CCO) will ensure this cost is not recovered as indirect costs.
You will be asked to remove the cost and charge it to a departmental account.
No. It does not become your personal property at the end of the project and its use must comply with university procedures regarding property.
Maybe. If a computing device is purchased on a project that is governed by FAR 52.245-1, that device may be titled to the Government, so it is important to be familiar with the project’s terms and conditions. When it is not titled to the Government or with the sponsor, the device is the property of the university and should be retained by the department after the end of the award for ongoing research activities, or for disposal in accordance with university policies. Contact email@example.com for more information.
If a computing device expense is deemed unallowable at any time, the cost will revert back to the PI and the PI's department for recovery from a departmental account.
Most sponsors will not allow a computer purchase at the end of the project. In fact, purchases made within six months of the project end date may be subject to more scrutiny from the sponsors. Check with your grant accountant to see if this can be charged.
The justification need not be very long, just briefly describe the purpose and benefit of the device on the project. For example: “the computer being used for data analysis is no longer functioning and needs to be replaced to complete the research”.
This would not be considered a conference cost because information would not be disseminated beyond collaborators that are working on the same sponsored project. This might be considered an official function, which requires prior approval from the sponsor.
No. Information must be disseminated beyond the non-federal entity (CU Boulder) per the Uniform Guidance guidelines.
If the primary purpose of the conference call is to disseminate technical information outside of CU Boulder, this may be an allowable conference expense. Please work directly with your OCG grants or contracts officer to document the purpose and attendees of this conference call.
If the breakout session is included as part of the original conference schedule, as opposed to a separately budgeted event, then it can be included. If this is an additional session above and beyond the scope of the original conference, then it would not be considered an eligible conference cost.
No, each individual is responsible for their own meal, which can be covered through travel costs if the individuals are in travel status.
Only meals for the participants may be paid for with participant support costs. If the sponsor-approved budget also included non-participant support costs, meals for the PI and staff may be allowable.
Food expenditures that occur while not in travel status or are not part of a sponsor approved conference are considered entertainment costs. On rare occasions, a non-federal sponsor may allow or even request non-programmatic related entertainment costs charged to their project. However, federal awards will pre-approve the direct charging of entertainment costs to a project only when they serve a specific programmatic purpose.
If this specific event was explicitly disclosed in the proposal budget justification and budgeted as a separate line item, the cost of this event would be allowed to post to the Participant Support category of the award.
This generally would not be an allowable entertainment cost, but may have the potential for a travel cost based on the scope of work (SOW) of the award, and any prior approval of the sponsoring agency.
Unless it has been clearly proposed in the award budget along with a budget justification, this would not be allowed. The sponsor would need to be contacted as prior written approval is required for this type of cost, and the cost must adhere to the PSC Procedural Statement: Recognition and Training.
The room rental would not be an allowable cost to post to the project, as it has no specific benefit to fulfill the research objective of the award.
It depends on the terms and conditions of the award. Some sponsors still require prior approval for equipment specifically listed in the award budget, while others do not. Refer to the award documents to determine the prior approval requirements, the award Terms and Conditions page in the Boulder eRA system, or contact firstname.lastname@example.org for assistance. For more information, see FAQs on OCG’s website.
No. Office furniture is considered general purpose equipment and is not allowable as a direct cost on an award.
Yes. In order for maintenance costs to be budgeted for on an award, the budget justification should include how the costs provide a direct and demonstrable benefit to the sponsored project.
It depends. If the total value of the new components is $5K or greater and they add enhancements and functionality with a useful life greater than one year that improves the functionality of the original equipment, the cost of the modifications can be added to the fabrication. However, if their total value is less than $5K or they only keep the equipment operational at its original performance level, the components are charged as supplies and not added to the fabrication. See the Sponsored Projects Property Control Manual for more details.
No. In order for this to be a capital upgrade, it must add to the permanent value of the original equipment by providing significant improvement to the functionality of that item, have an acquisition cost of at least $5K, and extend the useful life of the original equipment by at least one year. Since this upgrade is less than $5K, its cost could not be capitalized, it is not considered permanent equipment, and it would be charged as an operational expense.
Like & Unlike Circumstances
All costs charged to any sponsored project must be substantiated as to how they directly benefit and help fulfill the research objective of the project, as well as be allocable in amounts accurately representing the level of use on the project. This is true even for unlike circumstances in which costs that are normally treated as indirect can be direct charged. If the toner is for general office use, it would generally not be allowable. If the toner is to be used for a specific project purpose then you may be able to charge it if the sponsor allows. Check your sponsor requirements or contact your grant accountant if you have questions.
If the book provides instruction on a specific scientific method directly benefiting the research on a specific project this would meet the standard of an unlike circumstance. If a book is beneficial to broadening the PI’s knowledge in their field but does not serve a specific purpose on the sponsored project, the cost of the book would be considered an indirect cost and should not be direct charged to a sponsored project.
Yes, you may charge membership fees to the participant support project if there is budget available from the institutional allowance, and if the membership fees are in support of the participants. The institutional allowance may not be used to pay membership fees for the PI or other CU Boulder faculty or staff. It is not allowable to charge membership fees to NSF participant support awards that do not have an institutional allowance.
No. Individual membership fees are not allowed on federal awards. These types of costs are considered indirect costs covered by F&A. The membership can be purchased first on a separate transaction with non-sponsored funds, and then a second transaction can be made to pay only the conference registration fee with sponsored project funds.
Yes, with prior written approval from NIH, costs for travel and registration fees for the specialized training are allowable professional activity costs on the training grant.
If the candidate is being recruited to work on a sponsored project, the candidate’s meal would be an allowable cost as part of their travel expenses, either as a direct reimbursement or as a per diem charge. The PI and colleagues’ meal would not be an allowable expense because they are not in travel status.
Recruiting costs are not considered marketing costs and should be included under Other Direct Costs: Recrui
It depends. Please review your award documents and sponsor guidelines, and contact your Grant or Contract Officer for assistance. In general, if prior approval is required for international travel, prior approval will be required for international travel associated with recruiting.
If the cost of the airfare is going to be charged to a federally funded sponsored project that the candidate would potentially be working on, the air travel needs to comply with the Fly America Act even if the candidate will be purchasing the ticket and getting reimbursed for its cost.
Yes, costs of a recruitment search are allowable, even if the position ultimately is not filled.
It is possible to charge relocation costs, assuming no sponsor-specific restrictions. Contact your grant accountant to ensure that the cost is properly documented before any expenses are incurred.
This will require that you review the potential cost with your grant accountant. Some agencies may have more restrictive rules in place that only allow charging of relocation costs for employees working 100% on their specific funded project.
All international airfare charged to a federally-sponsored project must conform to the Fly America Act, even if we are doing a reimbursement rather than a direct purchase. Check the Travel Desktop Reference to see if the purchase conforms to the Fly America Act. If it does, then it can be charged to the project.
Yes, but documentation will be needed from the hiring company that this move is for the employee (an email or other document will suffice).
As long as the GRA will be working on the sponsored project for at least 12 months after coming to CU Boulder, and the PI can demonstrate that the GRA is essential personnel for the project, this is an allowable charge. The relocation costs should be detailed in the GRA offer letter.
As long as the form contains an explanation of how the position is allocable and necessary to the performance of the award and includes receipts for relocation costs. Use the “Reason” box on the form or attach the explanation as a separate document.
Purchase of furniture is not considered a relocation expense, so this would not be reimbursable as a relocation expense on a sponsored project.
NIH training grants and fellowships allow stipends. The NIH Grants Policy Statement states, “Stipends are not allowable under research grants even when they appear to benefit the research project”. Therefore stipends are not allowed on NIH research awards.
Departments should use the payment authorization form to pay the undergraduate students their stipend for attending the conference.
When a student has work expectations and service to the university is rendered, this is an employee/employer relationship, the pay is considered compensation, and the student should not be paid a stipend. The undergraduate student should be paid with the Student Assistant Job Code Series (4101 – 4106), depending on the level of the position. Payments for these job codes are posted on the financial statements in account code 407600 – Student Hourly Pay.
Here are two potential options to provide additional funding for students.
- The trainee may be able to receive stipend supplementation if provided from non-sponsored project funds. No service to the university for the stipend supplementation is required.
- Wages over and above the stipend could only be charged to a sponsored project if there is work effort on a sponsored project separate from the one funding the stipend. This is not allowed by all sponsors. Check sponsor requirements or contact your grant accountant for more information. If additional effort would cause the student to exceed standard graduate student full-time status, approval from the Graduate School will be needed.
While sponsor funding demonstrates approval, DOE, DPA and ARO generally have more restrictive terms that require pre-approval. Please note that the most restrictive terms on an individual award must be followed regardless of sponsor.
It depends on the purpose of the trip and if it directly benefits the research objective of the project. If the student is not supported by the project or is not providing a service to the project, it will be difficult to substantiate how his trip directly benefits the project.
The incidentals allowance is meant to cover fees and tips the traveler pays to baggage handlers or hotel staff, and other small miscellaneous items. The per diem allowance covers meal and personal expenses such as personal phone calls, laundry, movie rentals, or other entertainment costs while in travel status.
Different documentation is required for participants whose travel is supported by a participant support project. Please contact the project’s grant accountant for additional information.
This would not qualify as travel status eligible for meal or lodging reimbursement but you can be reimbursed for your mileage and parking fees. These can be direct charged to the project if the travel was necessary to and directly benefited the project being charged.
Choosing to stay in Denver for personal convenience would not qualify this trip for meals and lodging reimbursement. In order to qualify as an allowable sponsored project cost, the overnight stay must be necessary to complete the purpose of the trip and directly support the project being charged.
If a trip is cancelled due to no fault of the traveler, we generally allow those costs to be charged to the award. A credit is usually issued for the flight, and it is the department's responsibility to monitor the flight credits. If the credit ends up getting used to benefit another project, then the department needs to move the expenses to the proper funding source. If the award ends, and the department is unable to book a replacement flight and/or the credit expires before it can be used, then the expense should be moved to a nonsponsored funding source.
Same rationale as with airfare (with some exceptions-i.e. it depends). For example, conference is cancelled and traveler had option to stay at hotel (generally refunded in these cases), but the individual opted to stay at AirBnB or more restrictive option without cancellation. Due to COVID uncertainties and university guidance on PSC website updated as of September 2021, pre-approval is required for trips to assess benefits and risks and enhance safety of traveler.
In general, no. As of June 17th, 2020, with the expiration of OMB memo M-20-17 AND M-20-26, cancellation expenses and fees are no longer allowed to be charged to federal awards. Same goes with cancelled events.
Trip insurance should not be charged to sponsored awards. There were some flexibilities allowed during the height of the pandemic and with OMB memos, but those have since expired. Additionally, the coverage now usually excludes COVID coverage and only applies to luggage loss and personal injury protection. The University of Colorado provides travel insurance for university business international travel. Any domestic travel insurance coverage should be paid for by the traveler.
You may charge the visa application fees, including the filing fee and the Anti-Fraud Fee to the award if the researcher is essential and necessary for the project. Internal CU Boulder processing fees and any expedited processing fees cannot be charged to the sponsored project. The department should retain documentation from the PI that the prospective research associate is essential and necessary for the sponsored project.
No. Visa costs are only allowable as part of recruitment, not retention.
Rush or premium fees are not allowable as direct charges to a sponsored project. The department can pay for these fees through a departmental account.
Internal fees are not allowable as direct charges to a federal award per ISSS. In the event of a non-federal award, allowability is determined by the sponsor.
Unless the spouse is directly involved with work on that sponsored project, visa fees for spouses are not an allowable expense to sponsored projects.
No. Only those visa costs associated with the initial recruitment may be direct charged to a federal award.
Yes, this visa cost is an allowable travel charge to the sponsored project.
This would not be considered a recruiting cost; visas for collaborators may be allowable as travel costs. Contact the Office of International Students and Scholars for more information on appropriate visa types.