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Administrative and Financial

Unallowable Costs

Scope

Students, faculty and staff responsible for federal sponsored awards

General Policy Statement

The spending of any funds awarded by the federal government to Syracuse University (the "University") is governed by 2 CFR 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"), published by the United States Office of Management and Budget (OMB). The Uniform Guidance describes the principles to be applied in establishing the allowability of certain costs related to federally and other externally-sponsored programs at the University. These principles prohibit reimbursement from the federal government for certain unallowable costs.

Reason for Policy/Purpose

The University must comply with the federal regulations within the OMB Uniform Guidance governed by 2 CFR 200 Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Compliance with this policy is necessary to ensure continued federal funding for sponsored programs and activities.

Policy

Consistent with the OMB Uniform Guidance, 2 CFR 200, Subpart D - 200.300 Statutory and National Policy requirements and 200.309 Period of Performance, the University defines unallowable costs in the context of either a particular type of activity or a particular type of cost. Unallowable costs cannot be charged either directly or indirectly to the federal government.

  1. Direct Costs

    1. Costs incurred for the following types of activities are unallowable:
      • alumni activities and relations
      • commencement and convocation ceremonies
      • contingency provisions (reserves)
      • entertainment: amusement, diversion, and social activities and any costs directly associated with such costs such as tickets to shows or sports events, meals, lodging, rentals, transportation and gratuities
      • fund raising
      • goods and services for personal use such as automobiles
      • investment management
      • lobbying
      • public relations unrelated to the performance of a sponsored award
      • student activities: intramural activities, student publications, student clubs, and other student activities not specifically provided for in a sponsored award

    2. The following types of costs are unallowable:
      • alcoholic beverages
      • bad debt losses
      • first class travel
      • fines and penalties
      • internal interest expense
      • memberships in social, dining or country clubs
      • The allowable compensation for certain employees working on federally-funded research is subject to a federal ceiling. Salary charges above the federal salary ceiling are unallowable on federal awards.

    3. The University may identify other award costs as unallowable based on consideration of:
      • The sponsor's policies;
      • The award's terms and conditions;
      • University policies and procedures; and
      • Facts and circumstances associated with a particular award.

  2. Indirect Costs

    1. The following costs are ordinarily unallowable for direct charge to federal sponsors. However, they can qualify as indirect costs unless the item is for non-routine use that can easily and specifically be identified with an award, is required for its completion, and its purpose is justified with written documentation:
      • Advertising for goods, services or personnel essential for a particular award
      • Communications (local calls, postage, freight)
      • General purpose instrumentation or equipment
      • Administrative and clerical support

    2. Costs normally considered indirect costs such as those above (administrative salaries, postage and express mail, telephone, copier expenses, general purpose equipment) may be allowable as direct costs if they meet all three of the following unlike purpose or circumstance criteria:
      • An unlike purpose and circumstance exists in which a sponsored award requires resources beyond those normally expected for a typical research award
      • The cost can be associated with the specific sponsored award with a high degree of accuracy
      • Items ordinarily not allowed as direct cost items have been disclosed in the budget narrative submitted to the sponsor for approval, and the awarding agency has approved the cost as a direct expense in the awarded budget

    3. The Uniform Guidance section 200.413(c) states that "salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs." The University usually records administrative and clerical salaries as indirect costs. However, the OMB Uniform Guidance provides criteria that if met, allows for inclusion of administrative and clerical salaries as direct charges on federal awards. The Uniform Guidance criteria includes:
      • Administrative services are integral to an award or activity;
      • An individual or specific role can be specifically identified with the award or activity;
      • Such costs are explicitly included in the budget and/or have the prior written approval of the Federal awarding agency; and
      • The costs are not also recovered as indirect costs.

  3. Expenses

    Expenses on sponsored awards require careful review of the terms and conditions, and any other supporting documentation (e.g., approved budget, sponsor guidance) in order to determine the appropriateness of charges.

    Documentation is required to justify any expense charged to a sponsored award. The backup for expenditures should be adequate to support and justify that:

    • The expense provides a direct benefit to the award;
    • The expense complies with any award restrictions and approval requirements outlined in the terms and conditions of the award; and
    • If needed, the expense qualifies as "unlike purpose and circumstance" on a federal award.

  4. Enforcement

    All costs payable or reimbursable under University policy must be charged to the appropriate chartstring. For sponsored awards, it is the responsibility of the PI or PD to ensure that costs are charged to the appropriate chartstring.

    In the event that unallowable costs are charged to a sponsor, as determined by the Office of Sponsored Accounting, those costs will be transferred to the home department of the Principal Investigator (PI) or Project Director (PD).

    Administrative costs charged improperly to federal awards will result in unallowable costs, requiring reimbursement to the sponsor.

Appendices (as applicable)

  1. Procedures

    The PI and the academic department in receipt of federal or other external awards are responsible for implementing the following procedures:

    • Documenting the request for direct-charged administrative salaries in the budget and budget justification with sufficient detail to describe the necessary benefit to the award
    • Ensuring that only approved administrative salaries are direct-charged to awards on which those particular administrative salaries have been approved
    • Reviewing sponsored award expenditures throughout the lifecycle of the award to ensure that administrative salaries are appropriately charged

    For all relevant procedures, see the pre-award manual located on the Office of Sponsored Programs website at http://osp.syr.edu/, and the post-award manual located on the Office of Sponsored Accounting website at https://comptroller.syr.edu/.

  2. Definitions

    Administrative Salaries: provide non-technical supporting services that generally benefit departmental, institute, or center activities or objectives, including functions such as clerical support, financial management, procurement of materials and services, budget and planning, and personnel management.

    Allowable Costs: costs are allowed under both the provisions of federal guidance and the terms of a specific award.

    Allocable: the expense can be associated to an award with a high degree of accuracy. Chartstring: the mechanism by which Syracuse University tracks all financial transactions and activities in its financial system. For further details, refer to the Chart of Accounts Overview at: http://comptroller.syr.edu/comptroller/display.cfm?content_ID=%23((-)%0A.

    Direct Costs: these expenses can normally be directly charged to federal awards. However, the terms and conditions of the sponsored award must be reviewed prior to determining the appropriateness of expenses for each individual award.

    Federal Salary Ceiling: A legislative mandate limiting direct salary that an individual may receive under a National Institutes of Health (NIH) award. These caps are tied to Executive Level I pay scales. For current rate caps see: http://grants.nih.gov/grants/policy/salcap_summary.htm.

    Indirect Costs: sometimes referred to as facilities and administrative (F&A) costs or overhead. These expenses may not be charged as direct expenses to federal awards unless the costs meet the unlike purpose and circumstances criteria.

    Reasonable: the cost reflects what a "prudent person" would pay in a similar circumstance.

    Unallowable costs: costs that may not be charged to a federal award either as a direct charge or indirectly as recovered through (F&A) overhead rate.

    Unlike Purpose and Circumstance: generally an activity or cost which is substantially greater in amount or different in purpose than the normal use. Specifically, in order to direct charge a cost on a federal sponsored award that would ordinarily be charged as an indirect cost, the following requirements must be met before consideration:

    • The sponsored agreement has an extraordinary need for the item or service that is beyond the level of services normally provided by departmental administration;
    • The cost can be specifically identified to the work conducted under the sponsored agreement and is appropriately documented; and
    • The direct cost justification provides sufficient basis to classify an indirect cost as a direct cost.

  3. Forms

  4. Other Related Policies and Documents

Date: June 26, 2014
Amended:April 25, 2016


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