I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder regarding the use of funds from sponsored projects for relocation costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored research. Procedural statements support the CU Boulder Cost Principles Policy by providing definitions and processes for meeting those standards.
Relocation costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.464 as:
Relocation costs are costs incident to the permanent change of duty assignment (for an indefinite period or for a stated period of not less than 12 months) of an existing employee, or upon recruitment of a new employee.
Eligible employees are current employees with a 100% full-time equivalent appointment or new hires who will be in a 100% full-time equivalent appointment.
A. Federal Awards
Under the guidelines imposed by the Uniform Guidance, relocation expenses may be considered allowable direct charges under certain circumstances, subject to limitations.
CU Boulder considers relocation costs for new hires or existing employees to be allowable on sponsored projects if the position is essential and allocable to the performance of the award. Eligibility is limited to research faculty, research associates, and post docs.
A position is considered essential under the following conditions:
Relocation costs are allowable on sponsored projects, provided that all the following conditions apply, and are subject to limitations outlined below:
Limitations on Allowability
- For new hires, the relocation costs to be covered should be listed in the offer letter. If the cost is significantly higher than what the department historically has provided, the Tests of Propriety (section II.E of APS 4015 - Propriety of Expenses) should be used, and additional justification provided. Allowable relocation costs for current employees or new hires are limited to the items listed below:
- If the newly hired employee resigns within 12 months after hire for reasons within his or her control, all associated relocation costs must be removed from the federal award and charged to a departmental account. If the employee is terminated by the unit within 12 months, relocation costs can still be charged to the sponsored project.
- If an existing employee, or a new hire, is being moved to an overseas location, and both of the following conditions apply, the cost will be considered a travel cost in accordance with §200.474 Travel costs, and departments should follow the university's travel policy (link available in Section D.)
B. Non-Federal Awards
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, CU Boulder’s Cost Principles Policy, and related procedural statements, are also applicable to non-federal awards. The basic criteria for relocation costs are similar for non-federal sponsored projects, but it is also important to be familiar with the particular requirements or restrictions of each non-federal sponsor. When allowed by the non-federal sponsor, a written justification for the inclusion of relocation costs should be provided in order to explain why these are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project being charged, even when the non-federal sponsor may follow more flexible spending guidelines.
The relocation cost should be identified in the proposal budget justification if possible, and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval are meant to prevent questions regarding the allowability of costs in the event of an audit.
After an Award is Funded
Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted relocation cost is required after an award is funded, the department can work directly with the assigned grant accountant to ensure that this cost is properly documented (including any eligible charges paid by a new employee that would be reimbursed by CU Boulder with sponsored project funds). The documentation must be retained by the department and available upon request. The purpose and benefit of charging the relocation costs to the specific project should be fully described in the justification, and retained for future reference, should the expenditure be questioned at a later date.
D. Related Procedural Statements, Forms, Policies & Tools
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.
Some of your expenses may be considered travel expenses. Costs associated with this type of move would not be considered relocation costs. See the CU Travel Policy for more information.
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.