In an effort to best safeguard university funding, it is imperative that the university remains compliant with all regulations, terms and conditions imposed by each individual sponsor. If the university is not compliant, it risks a potential audit or loss of funding. Anyone authorizing the expenditure of sponsored project funds must learn the fundamentals of fiscal compliance and understand the cost principles contained in OMB Uniform Guidance.
OMB Uniform Guidance (UG)
OMB Uniform Guidance (UG) provides principles for determining costs applicable to research and development, training, and other sponsored work performed by colleges and universities under grants, contracts and other agreements with the federal government.
NC State Policy vs. Agency Terms and Conditions
Each awarding agency has the right to establish its own terms and conditions for its awards. Specific award terms and conditions take precedence over the provisions of UG. A sponsoring agency may authorize a directive that conflicts with NC State policy/guidance or a CAS (cost accounting standards) requirement. For example, although travel is not defined as unallowable in UG, your particular award may designate travel, or more likely foreign travel, as unallowable. In that case, you may not charge foreign travel to that project.
Direct vs. Indirect Costs
UG and the campus disclosure statement (DS-2) outline which costs are direct and which costs are indirect.
The cost principles as defined in Uniform Guidance provide the basis for determining the procedures used to identify direct costs. Costs incurred to support a project are treated as direct costs and are charged to sponsored projects when the costs can be specifically identified to the project with relative ease and with a high degree of accuracy.
Direct costs may be expensed to your sponsored project. The expense must meet all the tests for allowability. The sponsored project may bear the full amount of or the allocable portion of the expenditure. The expense is included in the financial report to the agency on the financial status report. Direct costs must be allowable per UG, NC State, the terms and conditions of the award document, and the DS-2. When the university handles a particular type of cost as a direct cost of sponsored projects, all costs incurred for the same purpose in like circumstances must be claimed as direct costs of all activities of the institution.
Indirect costs (F&A) are comprised of expenses that are not directly attributable to a specific sponsored project. Therefore, they are not charged to sponsored projects in the same manner as direct costs. Indirect costs are charged based on rates negotiated with the federal government. Indirect costs represent expenses that benefit university operations, including items such as administrative-staff salaries, electricity and NC State University Libraries.
Cost Accounting Standards (CAS)
The Cost Accounting Standards Board (CASB) provides guidelines on cost accounting practices, referred to as Cost Accounting Standards (CAS). CAS pertain to all awards, federal or nonfederal. While terms and conditions of specific awards may differ, the overriding principles that govern campus fiscal accountability must remain consistent. University practice may differ from agency policy. CAS was created for the following reasons:
- To prevent the charging of unallowable costs to federal awards
- To standardize university costing practices
- To standardize requirements for recipients of federal funds
Disclosure statements (DS-2)
UG requires that each university disclose in writing its cost accounting practices. The DS-2 for NC State identifies expenses as either direct or indirect charges. To avoid financial penalties, it is important that the university follows its disclosed practices when developing proposals or spending federal funds. Please email email@example.com with questions related to DS-2 disclosures.
Proposal and Award Spending Practices
An important component of cost accounting standards is proposing and spending award dollars in a consistent manner. The means by which we estimate costs when submitting a proposal should be consistent with the cost accounting practices used in reporting those costs. It is imperative that like expenditures made under like circumstances have the same accounting treatment. Expenses of a particular type should be consistently expended across campus.
Allowable vs. Unallowable Costs
An allowable cost meets the following conditions:
- The cost is reasonable (passes prudent person test)
- The cost is allocable (sponsored project benefits from the expenditure)
- The expense is treated consistently
- The cost is allowable as defined by UG or per the terms and conditions of the sponsored project*
*Specific award terms and conditions take precedence over the provisions of UG.
An unallowable cost is an expense that can’t be paid by your sponsored project. These costs are often explicitly disallowed by UG or university or state policy. NC State is charged with identifying and removing such costs before proposal submission, award billing or reporting.
When salaries or other activities are supported by two or more sources, issues arise as to how the direct costs should be allocated among the sources of support. In general, a cost that benefits two or more projects or activities in proportions that can be determined without undue effort or cost should be allocated to the projects on the basis of the proportional benefit.
NIH Childcare Cost Reimbursement
NIH recognizes that the high cost of childcare impacts graduate students and post-doctorates funded through NRSA fellowships, and their ability to successfully complete their training and fully participate in the extramural research workforce.
Process for NC State Departments/Colleges
Payment of childcare costs are to be processed via a voucher to the fellow:
Summer salary is any earnings paid through NC State University for work performed by 9-month faculty during the period between May 16 through August 15, including Maymester instruction.
A cost transfer is an expense that is transferred from one account to another after the expense was initially recorded in the financial accounting system.
Cost sharing is the portion of the total project costs of a specific sponsored agreement that is borne by NC State rather than the sponsor.
Federal regulations require that employees engaged in sponsored activities periodically review and certify their effort if costs for labor (salaries/wages, benefits) are charged directly to sponsored projects, cost-shared against a nonfederal funding source or funded from a federal appropriation.
Project Closeout is the process in which the award recipient demonstrates that all applicable administrative actions and all required work associated with the award have been completed.