Wayne State University's costing practices for grants and cooperative agreements comply with the Uniform Administrative Requirements, Cost Principles And Audit Requirements for federal grant awards. Unless otherwise indicated in the Notice of Award, or approved by the sponsor in the budget and Scope of Work or via prior written approval, the costs/activities allowed on Federal and State awards are governed by the applicable regulations stated here.
Allowable Costs
Generally, costs are considered allowable under grants when they have the following features:
- The costs are necessary, reasonable and allocable to the grant program;
- The costs comply with the limitations of a grant agreement as well as other applicable federal and state laws and regulations;
- The costs are accounted for consistently and in accordance with generally accepted accounting principles;
- The costs have not been allocated to or used to meet cost sharing or matching requirements of any other federal award in either the current or a prior period, except when allowed by federal law or regulation;
- The costs are adequately documented; and the net of all applicable credits is applied.
Allowability or Unallowability of Selected Cost Items
Unallowable costs are not eligible for reimbursement by the sponsor. Unallowable costs will be removed from the award cost center and placed on the departmental indirect cost center during the review or close out period unless a new funding source is provided by the department. Below is a list of costs normally considered unallowable. However, depending on the nature of the award and the sponsor specific agreement, some costs that are generally unallowable may be allowable for a specific award.
Expense categories listed below are provided for reference purposes and are not all inclusive.
The following categories provide guidance on when the expense may or may not be allowable on a state or federally funded project, as well as documentation that may be necessary to support the cost.
Costs that are typically unallowable may only be charged to your project account when specifically approved by the awarding agency in the award budget or correspondence from the grants officer.
Advertising and Public Relations
| Cost | Allowable | Unallowable |
| Advertising and public relations costs incurred solely for project purposes | X | |
| Gifts, souvenirs and costs to promote WSU | | X |
| Gifts based on custom or given as a thank you | | X |
Additional Information:
Examples of advertising and public relations expenses that are typically allowable include:
References
Alcoholic Beverages
| Cost | Allowable | Unallowable |
| Alcoholic Beverages | | X |
References
Alumni Activities and Contributions
| Cost | Allowable | Unallowable |
| Alumni Activities | | X |
| Contributions/Donations | | X |
References
Capital Expenditures
| Cost | Allowable | Unallowable |
| Building construction and/or land acquisition (unless it is the purpose of the award) | | X |
References
Entertainment
| Cost | Allowable | Unallowable |
| Entertainment costs including but not limited to amusement, diversion and social activities | | X |
Additional Information
Exceptions must be listed in the approved budget.
References
Equipment
| Cost | Allowable | Unallowable |
| Special purpose equipment used for project activities that has been approved by the agency or was included in the approved budget. | X | |
| General purpose equipment, buildings, land, or improvements to those items that materially increase the value. | | X |
| The capitalization of WSU labor costs used to fabricate equipment. | | X |
Additional Information
References
Fines and Penalties
| Cost | Allowable | Unallowable |
| Fines and penalties including late fees on invoices, special handling fees (rush payment fees, etc.) | | X |
References
Deficits on Other Awards or Contracts
| Cost | Allowable | Unallowable |
| Deficits on other awards including moving expenses from one account to another account due to lack of funds, or because grantor did not pay, etc. | | X |
References
Maintenance/Repair Costs
| Cost | Allowable | Unallowable |
| Maintenance/repair costs of necessary and specific project items | X | |
| Charges for general department or lab maintenance and repairs | | X |
References
Entertainment Expenses/Meals
| Cost | Allowable | Unallowable |
| WSU employee meals when travelling | X | |
| Meals as part of a project conference | X | |
| Meals for potenatal project personnel - recruiting | X | |
| Meals for Non- WSU, non-federal visitors or collaborators | X | |
| Meals for WSU employee participating in recruitment of non-WSU personnel | X | |
| WSU personnel meals when not travelling, except as identified below in additional information. | | X |
| Meal costs for WSU personnel participation in "working" meals | | X |
| Meals for meetings in which technical information is shared between WSU project personnel only (i.e. lab/staff meetings) | | X |
Additional Information
As indicated in the chart above, often meal expenses are considered unallowable. If meal expenses are submitted, they will be reviewed for allowability on a case-by-case basis, considering some or all of the following factors: Required documentation with meal transactions include: agenda, list of participants and business purpose.
References
Meetings/Conferences
A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond WSU personnel.
| Cost | Allowable | Unallowable |
| Meeting and conference costs when reasonable and necessary to a project (typically included in approved budget) | X | |
| Costs associated with meetings and conferences attended by only WSU personnel (not travelling) | | X |
Additional Information
Costs typically associated with a conference/meeting include: facility rental, A/V equipment costs, conference attendee lodging and meals, printing costs. Factors that affect the allowability of a conference/meeting include: business purpose and length and location of event
References
Membership, Subscription, and Professional Costs
| Cost | Allowable | Unallowable |
| Membership, subscription, and professional activity costs when they directly benefit the sponsored program | X | |
| WSU's membership in business , technical, and professional organizations | X | |
| Individual memberships that are in accordance with WSU's Administrative Policies and Procedures Manual (APPM) | X | |
References
Participant Support Costs
Participant Support Costs are costs for participants or trainees (but not employees) in connection with conferences, workshops, or training projects and may include stipends, subsistence allowances, travel costs and registration fees.
| Cost | Allowable | Unallowable |
| Participant support costs that have prior agency approval | X | |
| Costs related to WSU personnel | | X |
Additional Information
References
Personal Use Good or Services
| Cost | Allowable | Unallowable |
| Items used by WSU employees that are project-specific | X | |
| Personal use of goods and services | | X |
Additional Information
References
Pre-Award Costs
| Cost | Allowable | Unallowable |
| Expenses incurred prior to project start date | | X |
Additional Information
References
Professional Services
| Cost | Allowable | Unallowable |
| Professional services when costs are reasonable and necessary to prject objectives | X | |
| Speaker fees | X | |
| Honoraria | | X |
| Lump sum payments without a rate justification | | X |
References
Salaries and Wages
| Cost | Allowable | Unallowable |
| Faculty, technical staff and student pay at Institutional Base Salary (IBS) rates | X | |
| Administrative or clerical salary that is integral to the project or activity, includes individuals who can be specifically identified with the project or activity, are explicitly included in the budget or have prior written approval of the awarding agency, and the costs are not also recovered as indirect cost | X | |
| Non faculty overtime in compliance with employee contracts and when related to project activities | X | |
| Lump sum payments without a rate justification | | X |
| Faculty overload | | X |
| General administrative and clerical salaries | | X |
Additional Information
References
Scholarships/Fellowships
A scholarship or fellowship is typically paid as a stipend to the individual or as tuition payments and are made to encourage course/degree completion.
| Cost | Allowable | Unallowable |
| Agency approved scholarships/fellowships pauid on a sponsored program whose purpose is to provide training | X | |
| Scholarships/fellowships used as a mechanism to pay for services | | X |
Additional Information
References
Sponsorships
A sponsorship is a commitment to financially support an external entity for a specific activity.
| Cost | Allowable | Unallowable |
| Sponsorships with the purpose of providing funds to a project related event or activity | X | |
| Sponsorships viewed as donations | | X |
Additional Information
Sponsorships that provide funds to a project related event or activity are usually listed in the approved budget and may be justified by WSU participation in the event. A statement demonstrating the reasonableness of the cost should be included.
Supplies/Materials
| Cost | Allowable | Unallowable |
| Project supplies used for the performance of the award | X | |
| Computing devices that are essential and allocable to the project | X | |
| Office supplies | | X |
Additional Information
References
Telephone Charges
| Cost | Allowable | Unallowable |
| Long distance charges specifically identified to a project (i.e. who was called and how those called are affiliated with the project) | X | |
| Cell phone minutes, phone cards, or hardware needed for an international project | X | |
| Telephone charges, such as local and cell phone costs, not easily identifiable to the project | | X |
| Smart phones and related data plans | | X |
Additional Information
References
Travel
| Cost | Allowable | Unallowable |
| Travel costs such as transportation, lodging, and subsistence and related items incurred when necessary to support project activities | X | |
| Travel advance fee when necessary for documented project related travel or under special circumstances | X | |
| International transaction fee with receipt or bank/credit card statement | X | |
| Change fee for airfare with documented project related business purpose or under special circumstances | X | |
| Short term travel visa costs with documented business necessity | X | |
| Business/First class airfare or costs in excess of the least expensive commercial travel | | X |
| Dependent travel costs | | X |
| Extraordinary temporary dependent care costs | | X |
Additional Information
References
- Project personnel recruitment
- Program outreach
- Required communication/press releases
- Advertising for disposal of project materials
- 2 CFR 200.421 (General Provisions: Advertising and Public Relations)
- 2 CFR 200.423 (General Provisions: Alcoholic Beverages)
- 2 CFR 200.424 (General Provisions: Alumni/ae Activities)
- 2 CFR 200.434 (General Provisions: Contributions and Donations)
- 2 CFR 200.439 (General Provisions: Equipment and Other Capital Expenditures)
- 2 CFR 200.438 (General Provisions: Entertainment Costs)
- The cost of special purpose equipment should be charged to projects in proportion to its anticipated use and should be coded with appropriate equipment object codes.
- In order to avoid duplicate purchases, the Principal Investigator (PI) must provide the following certification. "I certify that this equipment is necessary and will be used for the project charged or in relative proportion to the projects to which the costs will be charged and that similar equipment is not available for use."
- Must be attached to Requisition or Purchase Order
- Labor costs used to fabricate equipment are considered a salary or contractual service cost and will be subject to the appropriate F&A.
- 2 CFR 200.439 (General Provisions: Equipment and Other Capital Expenditures)
- 2 CFR 200.318 (Procurement Standards: General Procurement Standards)
- 2 CFR 200.441 (General Provisions: Fines, Penalties, Damages and Other Settlements)
- 2 CFR 200.451 (General Provisions: Losses On Other Awards or Contracts)
- 2 CFR 200.452 (General Provisions: Maintenance and Repair Costs)
- Business purpose
- Length of event/meeting
- Location of event/meeting
- Participation of non-WSU employees
- Necessity of the expense
- Agency approved budget
- Agency or award specific guidelines
- 2 CFR 200.463 (General Provisions: Recruiting Costs
- WSU Administrative Policies and Procedures Manual (APPM): 1.3.1. Expense Guidelines
- Required documentation with conference transactions include: agenda, list of participants and business purpose
- A best practice procedure to document reasonable conference costs is having sign-in sheets for all conference attendees.
- 2 CFR 200.432 (General Provisions: Conferences)
- WSU Administrative Policies and Procedures Manual (APPM): 1.3.1. Expense Guidelines
- 2 CFR 200.454 (General Provisions: Memberships, Subscriptions, and Professional Activity Costs)
- WSU Administrative Policies and Procedures Manual (APPM): 1.3.1. Expense Guidelines
- Participant support costs must be separately identified in the agency approved budget
- This is a restricted budget category, any budget deviations out of this category requires agency approval.
- Exempt from F&A for all federal awarding agencies.
- 2 CFR 200.456 (General Provisions: Participant Support Costs)
- 2 CFR 200.1 (Acronyms & Definitions: Participant Support Costs)
- 2 CFR 200.308 (Revision of Budget and Program Plans)
- Examples of good and services that are the responsibility of the employee are GPS used to find a hotel, toiletries, and clothing.
- Examples of items used by employees that are project specific are bug spray in Africa, waders for work in streams, and medical shots required for international travel.
- 2 CFR 200.445 (General Provisions: Goods or Services for Personal Use)
- Many federal agencies, such as NSF and NIH allow for 90-day pre-award spending on grants without prior approval.
- 2 CFR 200.458 (General Provisions: Pre-Award Costs)
- Specific agency guidelines
- 2 CFR 200.459 (General Provisions: Professional Service Costs)
- WSU APPM 1.3.2 Special Payment Auhorization (SPA) 10-102A
- Faculty administrative increment(s) are included in IBS, but Health Care Service Component (HSRC) and Outside Work for Pay are not included in IBS. Administrative or clerical may be allowable when all the following criteria are met:
- Administrative or clerical services are integral to a project or activity;
- Individuals involved can be specifically identified with the project or activity;
- Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency;
- Administrative/clerical salaries on awards received prior to Dec. 26, 2014, will need to be justified, but will not require agency approval until a modification is received.
- The costs are not also recovered as indirect costs.
- Lump sum payments are discouraged because many agencies expect documentation to justify rates as the rate justification is a factor in determining the reasonableness of a cost.
- Faculty overload is generally unallowable because intra-institution consulting is assumed to be a part of faculty duties. Prior agency approval is necessary and may be granted when Faculty overload is paid across departmental lines and is in addition to regular responsibilities.
- Salary/payroll costs should be supported by completed time sheets (students/hourly pay) or Effort Report as appropriate.
- 2 CFR 200.430 (General Provisions: Compensation - Personal Services)
- 2 CFR 200.413 (Direct and Indirect (F&A) Costs: Direct Costs)
- Due to the nature of this type of expense, it is rarely allowed on research projects as the payments are not made in exchange for services, i.e. as an employee.
- Employee benefit packages may include a component for tuition or course reimbursement and are allowable as a fringe benefit.
- 2 CFR 200.466 (General Provisions: Scholarships and Student Aid Costs)
- When not charged solely to the project, appropriate allocation documentation should be maintained and may be reviewed.
- When project supplies are purchased near the end of a project, please refer to the Needed, Received and Used section of this policy.
- Office supplies can support numerous activities and are difficult to track for use to a specific project, and are therefore normally treated as an indirect cost, i.e. paid by General Fund accounts.
- Examples of supplies that are typically considered office supplies are toner, paper, pens, office furniture, business cards, printers, etc.
- 2 CFR 200.453 (General Provisions: Materials and Supplies Costs, Including Costs of Computing Devices)
- 2 CFR 200.413 (Direct and Indirect (F&A) Costs: Direct Costs)
- Local and cell phone costs can support numerous activities and are difficult to track for use to a specific project, and are therefore normally treated as an indirect cost, i.e. paid by General Fund accounts.
- 2 CFR 200, Appendix III
- 2 CFR 200.471 (General Provisions: Telecommunication Costs and Video Surveillance Costs)
- APPM Wireless Communication Devices, Services and Business Call Reimbursement 1.3.1.4
- Project related business purpose for the travel must be documented. Expenses are allowed when they are in accordance with WSU's travel policies: WSU Travel and Business Hosting Expense Policies and Procedures .
- Air travel must be compliant with the Fly America Act, if federally funded.
- Dependent costs may be allowable for travel with a duration of six months or more and with agency prior approval.
- 2 CFR 200.474 (General Provisions: Transportation Costs)
- APPM 7.1 WSU Travel and Business Hosting Expense Policies and Procedures