Ohio Admin. Code 3349-20-15 - Direct charging sponsored projects and unallowable costs
(A)
Purpose
The university is required to ensure that any costs charged to federally sponsored programs follow costing requirements set forth in the office of management and budgets ("OMB") uniform guidance (2 C.F.R. 200). This rule also provides a foundation for direct charging costs to other, non-federally sponsored programs.
(B)
Scope
This rule applies to all individuals involved in the decision making process for direct charging costs to sponsored programs.
(C)
Definitions
Consult rule 3349-7-01 of the Administrative Code.
(1)
"Direct Costs" refer to those costs that can be
identified specifically with a particular sponsored program. Direct costs must
also be allocated to one or more sponsored programs on a reasonable basis,
where those direct costs benefit multiple projects or activities. If a cost is
already included in the indirect cost rate (example, facilities and
administrative costs rate), then it should not be charged again as a direct
cost.
(2)
"Indirect Costs" or "Facilities and Administrative Costs
(F&A) " refers to those expenditures that have been incurred for common or
joint objectives and cannot be readily identified with a particular sponsored
program or activity. These costs consist of overall support of sponsored
research activities and are therefore recovered through the university's
F&A rate. Some examples include depreciation of buildings and equipment,
the costs of operating and maintaining facilities, utility costs, library costs
and general, department, and sponsored programs administration.
(3)
"Allowable Costs" are those costs that are necessary and
reasonable to perform the scope of work of the sponsored program. Allowable
costs must also conform to the terms and conditions of the sponsor, of the
award, and of the university's policies and procedures, the award terms and
conditions. Allowable cost should be substantiated, by proper documentation or
justification, to support its allocation to the sponsored program(s) being
charged.
(4)
"Allowable Costs" are those costs that are necessary
and reasonable to perform the scope of work of the sponsored program. Allowable
costs must also conform to the terms and conditions of the sponsor, of the
award, and of the university's policies and procedures, the award terms and
conditions. Allowable cost should be substantiated, by proper documentation or
justification, to support its allocation to the sponsored program(s) being
charged.
(5)
"Sponsored Program" refers to an award funded via a
grant, contract, cooperative agreement or subcontract from a federal, state or
local government entity, the private sector, or an institution of higher
education, whereby the university agrees to perform a certain scope of work, in
accordance with terms and conditions set by the sponsor, for specific, budgeted
monetary compensation.
(6)
"Allocable Costs" refers to costs incurred to benefit a
sponsored program and charged based on the proportional benefit of that cost to
the sponsored program. If a cost benefits multiple sponsored programs and/or
other university activities, then the costs must be allocated
accordingly.
(a)
If a cost benefits two or more projects or activities,
it must be charged in accordance with its benefits to each project
respectively. Charges split between more than one grant must be split on the
basis of proportional benefit or other reasonable method. The division of the
expenditure cannot be split based on available funding or any other type of
synonymous methodology. An expenditure that benefited two or more projects
cannot be charged solely to one project because of funding constraints on
another project.
(b)
Any costs allocable to a particular project may not be
shifted to other sponsored programs in order to meet deficiencies caused by
overruns (deficits) or other fund considerations. Costs cannot be shifted to
avoid restrictions imposed by law, by terms of the sponsored program, or for
other reasons of convenience.
(7)
"Consistent
Treatment" means that each item of cost incurred for the same purpose must be
treated consistently in like circumstances either as a direct or an indirect
F&A cost in order to avoid possible double-charging of federal
awards.
(8)
"Reasonable Costs" refers to costs incurred that
reflect the judgment a prudent person would have used under the circumstances
prevailing at the time of the decision. Costs must be reasonable relative to
the nature or type of cost incurred and the price paid for the items in
relation to the benefit received.
(D)
Body of the
rule
Costs to sponsored programs must meet the following criteria:
(1)
Be adequately documented.
(2)
Must be charged
accordingly as either a direct cost or an indirect cost
F&A.
(3)
Must be a reasonable costs, allocable costs, allowable
costs, be accorded consistent treatment in order to be charged to the
grant.
(4)
Must not be included as a cost or cost-sharing
requirement of any federally-funded sponsored program unless allowed under
specific statute and sponsor approval.
(5)
May include
unlike circumstances where costs that are normally F&A types of costs (such
as administrative and clerical salaries, computing devices, memberships, office
supplies and postage) may be directly charged, when all of the following
criteria have been met:
(a)
The costs are integral to a project or
activity;
(b)
The costs can be specifically identified with the
project or activity;
(c)
The costs are explicitly included in the budget or have
the prior written approval of the federal awarding agency; and
(d)
The costs are not
also recovered as indirect costs.
(6)
May allow a
typically unallowable costs in special circumstances with prior written
approval from the sponsor.
Notes
Promulgated Under: 111.15
Statutory Authority: 111.15
Rule Amplifies: 3350.12
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