Unallowable Costs - Reasonableness Doctrine Policy

1. Purpose of Policy

To set forth how WMU intends to comply with Code of Federal Regulations Title 2: Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2CFR Part 200) with regard to costs that are identified as unallowable by the federal government.

2. Stakeholders Most Impacted by the Policy

This policy applies to WMU employees who work with federally funded awards issued under sponsored awards made to Western Michigan University.

3. Key Definitions

3.1. Directly associated costs means any cost that is generated solely as a result of the incurrence of another cost, and which would not have been incurred had the initial cost not been incurred.  E.g., Costs of entertainment are unallowable, including amusement, diversion, social activities, and any costs directly associated with such costs that are not allowable (e.g., tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities). 

4. Full Policy Details

Unless otherwise indicated for a specific type of cost, unallowable costs must be excluded from direct and indirect charges to federally sponsored agreements. Unallowable, directly associated costs will also be excluded from charges to federally sponsored agreements. Unallowable costs may be charged to non-federal accounts but must be specifically identified by object code for F&A cost purposes.  See link to Unallowable Costs – Reasonableness Doctrine Procedure below.

5. Accountability

5.1. Failure to adhere to Federal regulations may result in the withholding of new awards.

5.2. Additional consequences for non-compliance include possible individual discipline for failure to follow applicable University policies and requirements.

6. Related Procedures and Guidelines

Unallowable Costs – Reasonableness Doctrine Procedure