|Enforcement official||Associate Vice President for Research|
|Classification||Board of Trustees-delegated Policy|
|Category||17. Research and Intellectual Property|
Statement of policy
The purpose of this policy is to identify the principles used to determine whether costs incurred at Western Michigan University are allowable or unallowable as direct costs or as facilities and administrative costs. The policy applies to both costs charged to sponsored agreements and cost sharing.
Summary of contents/major changes
Moved policy to template; technical changes.
1. Purpose of Policy
The purpose of this policy is to comply with 2 CFR 200 Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and federal agency policies for federally funded projects. The principles deal with determining costs, identifying allowable and unallowable costs, and defining direct and Facilities & Administrative costs.
2. Stakeholders Most Impacted by the Policy
This policy applies to all Principle Investigator(s) (PI) engaged in research, projects, activities conducted under the auspices of Western Michigan University whether the activities are conducted on or off campus.
3. Key Definitions
3.1. Facilities & Administrative (F&A) Costs - those costs associated with the infrastructure that supports the costs of the research mission and includes buildings and their maintenance, libraries, and administrative costs which cannot easily be determined for each project.
4. Full Policy Details
Expenses incurred on sponsored program accounts must be allowable, reasonable, allocable, and consistently treated between a direct cost and something normally treated as an indirect or an F&A cost. Sufficient documentation must be available (attached to transaction, maintained in department, etc.) to demonstrate that the basic cost principles are met.
4.1. Allowable: The cost must comply with the policies and procedures of WMU, as well as the specific project terms and conditions of the agreement, and be adequately documented: 2 CFR 200.403
4.2. Reasonable: The cost does not exceed that which would be incurred by a prudent person; 2 CFR 200.404
4.3. Allocable: The cost does must be allocated to the project(s) in accordance with the benefits received; 2 CFR 200.405
4.4. Consistently Treated: The cost must be accorded consistent treatment; i.e. an expense may not be charged to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the award as an indirect cost; 2 CFR 200.403
4.5. In addition to all above, allowable project expenses must be needed, received and used within the project period.
4.6. Needed, Received and Used
- 4.6.1. Expenditures that occur close to the project end date need to be reviewed with the "needed, received, and used" concept. Allowable purchases during the last three months of a project need to meet the following criteria:
- 18.104.22.168. Needed to complete the project objectives
- 22.214.171.124. Be allowable according to the cost principles, and
- 126.96.36.199. Be purchased and used during the project period
- 4.6.2. Exceptions to Needed, Received and Used
- 188.8.131.52. Publications costs (within the 90 – 120 closeout period) with specific agency approval.
- 184.108.40.206. Pre-award costs and continuing projects, when allowed and funded by the agency
5.1. The responsibility for compliance with University, Federal, and agency regulations and guidelines and for maintaining supporting documentation for transfers/adjustments resides in the originating department/unit. Deans, Directors and Chairs. Those who have authority to approve adjustments are also responsible and accountable for compliance with University and agency regulations.
5.2. Any audit-derived disallowed cost will be borne by the department(s) that caused them.
5.3. Additional consequences for non-compliance include possible individual discipline for failure to follow applicable University policies and requirements.
6. Related Procedures and Guidelines
7. Additional Information
|Effective date of current version||October 1, 2019|
|Date first adopted||November 3, 2003|
|Proposed date of next review||October 1, 2022|
|Certified by|| |
Director of Grants and Contracts, Office of Research and Innovation
|At the direction of|| |
Vice President for Research