Procedures for Determining Costs

Procedures for Determining Costs Allowability on Sponsored Agreements and Identifying Direct and Indirect Costs on Federal Awards

Note: For all sponsored projects, always refer to the award's specific terms and conditions, which may include additional restrictions on cost allowability, or contact your SPA Representative

Payment Type Federal Sponsor State Sponsor Private Sponsor
Advertising Allowable when necessary to meet the specific requirements of the sponsored agreement Same as Federal sponsors Same as Federal sponsors
Alcoholic beverages Unallowable Unallowable Unallowable
Books and journals Allowable when necessary to meed the specific requirements of the sponsored agreement; otherwise provided as part of the University's library services Same as Federal sponsors Same as Federal sponsors
Consulting services Costs of consultant services rendered by persons who possess a special skill and who are not officers of employees of the University are allowable Same as Federal sponsors Same as Federal sponsors
Donations and contributions Unallowable Unallowable Unallowable
Entertainment Unallowable Unallowable Unallowable
Equipment - special purpose (e.g., scientific equipment) Allowable provided that items with a unit cost of $5000 or more have the prior approval of the sponsor Allowable with prior approval Same as State sponsors
Equipment - general purpose (e.g., office, computer equipment) Unallowable, except where approved in advance by the sponsor Same as Federal sponsors Same as Federal sponsors
Goods and services for personal use Unallowable Unallowable Unallowable
Insurance Costs of insurance required or approved pursuant to the sponsored agreement are allowable; otherwise treated as an F&A cost Same as Federal sponsors Same as Federal sponsors
Materials and supplies Allowable when necessary to meet the specific requirements of the sponsored agreement Same as Federal sponsors Same as Federal sponsors
Office supplies Unallowable as a direct cost, except where extensive use of office supplies is necessary to meet the requirements of the sponsored agreement Allowable, provided the supplies are reasonable and directly related to the work of the sponsored agreement Same as State sponsors
Meetings and conferences Allowable provided the primary purpose of the meeting or conference is the dissemination of sponsored agreement-related information Same as Federal sponsors Same as Federal sponsors
Memberships, subscriptions, and professional activity costs Generally unallowable as a direct cost except when necessary to meet the technical requirements of the award. The cost of membership in any civic or community organization is unallowable. Same as Federal sponsors Same as Federal sponsors
Postage Unallowable as a direct cost, except when extensively used (FedEx, UPS, etc....) or necessary to meet the technical requirements of the award Allowable provided the postage is reasonable and directly related to the work of the sponsored agreement Same as State sponsors
Proposal development costs Unallowable as a direct cost Same as Federal sponsors Same as Federal sponsors
Prizes & Awards

Unallowable. See 2 CFR §200.445

Unallowable Unallowable
Professional journal publications Allowable where the article reports sponsor-supported work and the costs are levied impartially on all papers published by the journal Same as Federal sponsors Same as Federal sponsors
Scholarships - Merit Allowable only when the purpose of the sponsored agreement is to provide training to selected participants and the charge is approved by the sponsor. See 2 CFR §200.466 Same as Federal sponsors Allowable when approved in advance by the sponsor
Taxes Unallowable when exemptions are available to the University (e.g., sales tax) or are available to the University based on exemptions afforded the Federal government Same as Federal sponsors Same as Federal sponsors
Telephone - local Unallowable as a direct cost Same as Federal sponsors Same as Federal sponsors
Travel - domestic Allowable provided the travel is reasonable and related to the work of the sponsored agreement Same as Federal sponsors. However, domestic travel is generally restricted to New York State. Same as Federal sponsors
Travel - international Allowable provided the travel is reasonable, directly related to the work of the sponsored agreement, and compliant with the requirements of the Fly America Act Generally unallowable unless specifically approved in advance Allowable when approved in advance by the sponsor
Tuition Remission Allowable for graduate students and Ph.D. candidates at 50% of the University's published tuition rates. The charge must be approved in advance by the sponsor Same as Federal sponsors Same as Federal sponsors

Salary, Wages, and Stipends

Payment Type Federal Sponsor State Sponsor Private Sponsor
Faculty and professional staff Allowable provided the salary is reasonable, directly related to the work of the sponsored agreement, and documented in accordance with 2 CFR §200.430 Allowable provided the salary is reasonable, directly related to the work of the sponsored agreement, and documented in accordance with University procedures Same as State sponsors
Summer salary Allowable at a rate (26.3%) not in excess of the base salary divided by the period to which the base salary relates. Same as Federal sponsors Same as Federal sponsors
Post doctoral associate Allowable provided the salary is reasonable, directly related to the work of the sponsored agreement, and documented in accordance with 2 CFR §200.466 Allowable provided the salary is reasonable, directly related to the work of the sponsored agreement, and documented in accordance with University procedures Same as State sponsors
Administrative and clerical staff

Unallowable as a direct cost unless the following conditions are met (2 CFR §200.413):

(1) Administrative or clerical services are integral to a project or activity;
(2) Individuals involved can be specifically identified with the project or activity;
(3) Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
(4) The costs are not also recovered as indirect costs.

Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement, and documented in accordance with University procedures Same as State sponsors
Graduate Assistant wages Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement, and documented in accordance with 2 CFR §200.430 Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement, and documented in accordance with University procedures Same as State sponsors
Graduate Teaching Assistants salary Allowable only when the purpose of the sponsored agreement is instruction or training, the charge is approved in advance by the sponsor and documented in accordance with 2 CFR §200.430. Same as Federal sponsors Same as Federal sponsors
Graduate Research Assistant stipend Allowable when a degree seeking graduate student performs original, professional research related to his or her academic program. The student must be fully matriculated in a graduate or Ph.D. degree program and be under the supervision of an appropriate faculty member Same as Federal sponsors Same as Federal sponsors
Other Stipends Allowable only when the purpose of the sponsored agreement is to provide training to selected participants and the charge is approved by the sponsor Same as Federal sponsors Same as Federal sponsors
Student Wages - Academic Year Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement, and documented in accordance with 2 CFR §200.430 Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement, and documented in accordance with University procedures Same as State sponsors
Other Student Wages - Summer Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement and documented in accordance with 2 CFR §200.430 Allowable provided the wages are reasonable, directly related to the work of the sponsored agreement, and documented in accordance with University procedures Same as State sponsors

Definitions

Allowable Costs

2 CFR §200 Subpart E- Cost Principles identifies direct and indirect costs that may be charged to federal grants and contracts, otherwise known as sponsored agreements.  2 CFR §200 Subpart E also identifies those charges that cannot be charged to sponsored agreements and are considered unallowable expenses. 2 CFR §200 Subpart E offers the factors affecting the allowability of costs applied to federally sponsored agreements.

Allowable costs must be:

  1. Reasonable - For a cost to be considered reasonable, it must be necessary for fulfillment of the agreement, acquired by means consistent with federal and state laws and regulations, and consistent with University policies and practices.
  2. Allocable - A cost is allocable to a sponsored agreement if the goods/services involved are charged in accordance with the relative benefits received by that agreement. To be considered allocable, a cost must be incurred solely to advance the work under the sponsored agreement or benefit both the sponsored agreement and other work of the institution in proportions that can be approximated through use of reasonable cost allocation methods.

    Note: Any cost that is allocable to a particular sponsored agreement may not be moved (e.g., cost transfer) to another sponsored agreement in order to meet deficiencies caused by overruns or other funding considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.
  3. Treated consistently throughout the University - similar costs normally cannot be treated as both direct and indirect costs.
  4. Conform to any limitations or exclusions in the sponsored agreement.

Direct Costs

According to 2 CFR §200.413, direct costs are those costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.

  • compensation of employees for performance of services under the sponsored agreement including related benefit costs;
  • costs of materials consumed or expended in the performance of the work;
  • travel, including expenses for transportation, lodging, subsistence, and related items incurred by employees who are traveling on official business directly related to the sponsored project

Indirect/F&A Costs

Costs incurred for common or joint objectives which cannot be identified specifically with a particular sponsored project are treated as indirect costs. Examples include:

  • utilities, maintenance and operation
  • building and equipment use expenses
  • administrative costs (see details below)
  • library costs
  • student service costs

Most sponsored agreements include a percentage of the direct cost to cover these charges known as the Facilities and Administrative Cost Rate (F&A).

Administrative Costs

Federal regulations limit instances where administrative costs can be charged to grants and contracts. The following is a list of the types of expenses that are generally not allowable as a direct cost per the Federal government. An exception may be made if there is EXTENSIVE use of such expenses, the expenses have been properly justified/documented in the grant/contract proposal, and they have been approved as a direct cost by the appropriate federal agency.

The most common administrative costs are:

  • Administrative and clerical salaries and wages
  • Printing and copying costs
  • Office supplies
  • Postage and mail
  • Telephone and internet expense