Allowable Costs on Sponsored Projects: Policy & Operational Procedure

Transcription

1 Allwable Csts Plicy Allwable Csts n Spnsred Prjects: Plicy & Operatinal Prcedure Plicy Sectins Plicy Statement Reasn fr Plicy Wh Shuld Knw This Plicy Cntacts Applicable ACP Plicies Determinatin f Allwability at ACP Rles & Respnsibilities Appendix: Applicable Federal Regulatins & Criteria Last Revised: April 2014 Plicy Statement It is the plicy f the Aspen Center fr Physics (ACP r the Center) t charge csts t spnsred prjects in a manner cnsistent with Office f Management & Budget (OMB) Circular A- 122, spnsr plicies, and award terms and cnditins. This Plicy and Operatinal Prcedure ensures that csts charged t a spnsred award are allwable, allcable, reasnable, and accunted fr cnsistently. Reasn fr Plicy As a recipient f Federal funding, ACP is subject t numerus financial accunting and cmpliance standards, including but nt limited t thse set frth in OMB Circular A-122. Failure t adhere t the prvisins f this Plicy and Operatinal Prcedure may result in the Center s spnsrs, r ther gvernment agencies, disallwing csts r impsing ther sanctins. Wh Shuld Knw This Plicy! Principal Investigatrs! Administrative Staff " Winter Cnference/Summer Wrkshp Organizers! Prpsal Cmmittee

2 ! Officers " Trustees " General Members " Other: Cntacts Subject Plicy Questins Finance Prcedure Questins Cntact Crprate Secretary Administrative Vice President Finance Manager Applicable ACP Plicies Participant Supprt Csts: Plicy & Operatinal Prcedure Spnsred Prject Prgram Incme: Plicy & Operatinal Prcedure Direct & Indirect Charging f Spnsred Prjects: Plicy & Operatinal Prcedure Chart f Accunts: Operatinal Guidance Determinatin f Allwability at ACP Intrductin and Definitin: This Plicy and Operatinal Prcedure defines the allwable csts n ACP s spnsred prjects. Because spnsrs award prjects t the Center fr a specific purpse, funds may nly be spent t further the prject s bjectives and in accrdance with all applicable cst allwability rules. Fr purpses f this Plicy and Operatinal Prcedure, ACP defines a spnsred prject as any grant, cntract, r ther agreement between ACP and the Federal gvernment r ther grantr agency. (This des nt include dnatins r gifts frm individuals r crpratins.) Determining Allwable Csts: Allwable csts are thse that are reasnable, allcable, accunted fr cnsistently, and nt specified as unallwable by the terms f the award r spnsr regulatin r plicy, i.e., OMB Circular A- 122, the NSF Award & Administratin Guide and ther applicable spnsr regulatins. It is the respnsibility f the Principal Investigatr, supprted by Administrative Staff, t mnitr the award and ensure that all csts charged t an award meet the applicable criteria.

3 Allwability f Specific Items f Cst: This sectin addresses hw this Plicy and Operatinal Prcedure applies t specific types f csts cmmnly incurred at ACP, and fcuses n the majr factrs t be cnsidered, including restrictins and guidelines f the award spnsr, when determining allwability fr specific items f cst. Persnnel Expenses: Cmpensatin (Salaries, Wages and Fringe Benefits): Salaries, wages, and fringe benefits fr persnnel (ACP Administrative Staff) are allwable csts n spnsred prjects t the extent that the amunt charged is reasnable in relatin t the wrk perfrmed. Nn- Persnnel Expenses: Participant Supprt: The majrity f direct csts awarded t and expended by ACP n spnsred prjects are in the Participant Supprt categry. Participant Supprt csts are fr items such as stipends r subsistence allwances, travel allwances, and registratin fees paid t r n behalf f participants at ACP (but nt emplyees) in cnnectin with the Summer Prgram and Winter Cnferences. These csts are allwable with the prir apprval f the awarding agency. Participant Supprt travel csts must meet the criteria established in the ACP travel prcedures and any additinal travel guidelines r regulatins utlined in the spnsred prject award dcument. Participant Supprt expenses that meet these guidelines and that were included in the awarded budget require n further apprval and can be directly charged t a spnsred prject. If Participant Supprt was nt included in the awarded budget, refer t the specific spnsr guidelines regarding the allwability f Participant Supprt as sme spnsrs may require prir apprval f the csts. Supplies: Supplies are allwable if they are purchased t directly benefit the prject. Clerical and Office Supplies are allwable in certain circumstances where they are necessary t cmplete the prject, will nt be used n anther prject and can be allcated t the spnsred prject with a high degree f accuracy. Meals & Entertainment: Generally, csts assciated with entertainment are nt allwable n spnsred awards. Examples f items that are nt allwable as Entertainment Expenses are listed belw: Alchl Magazines/Newspapers Mvies Flwers Gifts/Suvenirs Cncerts/Events

4 Meals assciated with an activity that specifically furthers the gals f a spnsred prject (such as a pster sessin at a specific Winter Cnference) may be charged as a direct cst t the spnsred prject nly when explicitly included in the prject budget Other: Additinal types f nn- persnnel csts incurred by ACP are allwable t the extent that they are allwable per the spnsr regulatin and award terms and cnditins and the amunt charged reflects the prprtinal benefit received. Cntrl Envirnment Prgram budgets are set annually by a cllabratin with the Treasurer and Finance Manager and are apprved by the Trustees. The Finance Manager cdes expenses within the parameters f these budgets. The Administrative Vice President reviews expense cding and immediately crrects any errrs r departures frm plicy. Shuld there be any misuse f funds, PIs and Officers will immediately direct a cst transfer (see ACP Cst Transfers Plicy). PIs review grant expenses quarterly and will address questined csts within the next 30 days. The ACP Spnsred Prgrams Reference Manual gives mre guidance n allwability and is distributed t all parties invlved with financial grant management. In additin t the Manual, the ACP Prcurement Plicy prvides a list f unallwable expenses. Indirect Csts are als discussed in the Manual and in the Indirect Cst Rate Prpsal. Risk Assessment: Changes t the financial reprting system including the cst accunting systems will adhere t all ACP financial plicies and prcedures and will be made in rder t cmply with federal regulatins r in rder t prvide better accunting fr the Center. The President, Treasurer and Administrative Vice President, and the Cmputer Cmmittee if cmputing changes are invlved, will be cnsulted n majr sftware changes and the Administrative Vice President and/r PIs will be cnsulted n accunting changes made t imprve federal cmpliance. Due t the small nature f the Center, management is able t review all transactins s unallwable expenses are easily detected. In additin, the Center s accunting system is in the Clud, s is fully accessible t management. Cntrl Activities T ensure cnsistent distributin f charges, ACP has prepared a Chart f Accunts dcument delineating the prper use f all general ledger cdes. See Chart f Accunts Definitins: Operatinal Guidance in this Manual. The Finance Manager will update the ACP Bkkeeping Manual, the ACP Plicies and Prcedures Manual, the ACP Spnsred Prgrams Reference Manual, the ACP website and database as needed when there is a plicy r prcedural change.

5 Cmputatinal accuracy is ensured fr GL accunts tied t the ACP database fr prgram incme (ties t registratin fees) and recnciliatins are dne each seasn. The Finance Manager reviews all cding t make sure the prper bject cde was used. See the ACP Cst Transfers Plicy fr prcedures fr crrecting unallwable r miscded expenses. When a new expense is incurred, dcumentatin is reviewed t cde it t the crrect fund and allwable r unallwable bject cde. Cnsult the Rles & Respnsibilities dcument in this manual fr the segregatin f duties between review and authrizatin f csts. Training is cnducted fr staff, fficers and PIs s they will be knwledgeable abut allwable csts. Trainings are recrded fr each individual in the ACP database. Infrmatin and Cmmunicatin Due t ACP s annual schedule, the ACP Bard meets nce in July and nce in August. Financial reprts are prepared fr Bard disseminatin and study fr ne f thse meetings. An annual budget is prepared at that time. PIs review quarterly Revenue and Expense reprts t check allwable expenses and t track budget t current. Allwable expense and ther plicies are psted n the ACP website. Internal manuals are circulated t the respnsible parties. ACP management and staff cmmunicate regarding csts that diverge frm standards. Shuld emplyees find an anmaly there is a Whistleblwer Plicy in place if rdinary methds f righting a knwn prblem are ineffective. Emplyees sign a prcurement standard upn emplyment and receive training as needed n allwable csts. The ACP subscribes t Plicies and Prcedures - All NSF Plicies and Prcedures fr Natinal Science Fundatin Update s receives s frm its cgnizant agency. Staff des have access t grant agreements and grant circulars. Mnitring The Administrative Vice President, as the PI s designee, reviews all supprting dcumentatin fr allwable expenses. Quarterly grant reviews and annual Bard reprts n budgets allw management t cmpare budget t actual. Shuld an egregius variance ccur, the Treasurer will investigate. ACP cntracts fr an annual external audit, which cmpares prir year expenses t current. At an annual exit meeting, the auditr infrms fficers f any prblems. Management fllws up n the auditrs recmmendatins fr imprvement and/r cmpliance. Management is included and usually is the key cmmunicatr n s frm federal agencies.

6 Rles & Respnsibilities Principal Investigatr: Respnsible fr understanding spnsr and ACP regulatins and fr ensuring that csts are charged t spnsred prjects are allwable per spnsr regulatins and ACP plicy. Administrative Staff: Respnsible fr dcumenting transactins in cmpliance with this plicy and fr retaining dcumentatin, justificatin and back- up fr transactins. This dcumentatin shuld include an explicit explanatin as t hw the cst benefited the spnsred prject. Serve as a resurce fr the PI in determining the allwability f csts. Prpsal Cmmittee: Respnsible fr preparing prpsal budgets in cmpliance with this plicy and applicable spnsr regulatins. Designated Officers: Respnsible fr supervising the Administrative Staff and reviewing and apprving certain transactins and financial reprts fr cnsistency and cmpliance with spnsr regulatins and ACP plicy. Appendix: Applicable Federal Regulatins & Criteria ACP must cmply with the OMB Circular A- 122, Cst Principles fr Nn- Prfit Organizatins, as it pertains t direct and indirect csts charged t Federal awards. Cmpliance with A- 122 is implicit in this plicy. (Current versin revised May 10, 2004.) GENERAL PRINCIPLES A. Basic Cnsideratins 2. Factrs affecting allwability f csts. T be allwable under an award, csts must meet the fllwing general criteria: a. Be reasnable fr the perfrmance f the award and be allcable theret under these principles. b. Cnfrm t any limitatins r exclusins set frth in these principles r in the award as t types r amunt f cst items. c. Be cnsistent with plicies and prcedures that apply unifrmly t bth Federally financed and ther activities f the rganizatin. d. Be accrded cnsistent treatment. e. Be determined in accrdance with generally accepted accunting principles (GAAP). f. Nt be included as a cst r used t meet cst sharing r matching requirements f any ther Federally financed prgram in either the current r a prir perid. g. Be adequately dcumented. 3. Reasnable csts. A cst is reasnable if, in its nature r amunt, it des nt exceed that which wuld be incurred by a prudent persn under the circumstances prevailing at the time the decisin was made t incur the csts. The questin f the reasnableness f specific csts must be scrutinized

7 with particular care in cnnectin with rganizatins r separate divisins theref which receive the prepnderance f their supprt frm awards made by Federal agencies. In determining the reasnableness f a given cst, cnsideratin shall be given t: a. Whether the cst is f a type generally recgnized as rdinary and necessary fr the peratin f the rganizatin r the perfrmance f the award. b. The restraints r requirements impsed by such factrs as generally accepted sund business practices, arms length bargaining, Federal and State laws and regulatins, and terms and cnditins f the award. c. Whether the individuals cncerned acted with prudence in the circumstances, cnsidering their respnsibilities t the rganizatin, its members, emplyees, and clients, the public at large, and the Federal Gvernment. d. Significant deviatins frm the established practices f the rganizatin which may unjustifiably increase the award csts. 4. Allcable csts. a. A cst is allcable t a particular cst bjective, such as a grant, cntract, prject, service, r ther activity, in accrdance with the relative benefits received. A cst is allcable t a Federal award if it is treated cnsistently with ther csts incurred fr the same purpse in like circumstances and if it: (1) Is incurred specifically fr the award. (2) Benefits bth the award and ther wrk and can be distributed in reasnable prprtin t the benefits received, r (3) Is necessary t the verall peratin f the rganizatin, althugh a direct relatinship t any particular cst bjective cannt be shwn. b. Any cst allcable t a particular award r ther cst bjective under these principles may nt be shifted t ther Federal awards t vercme funding deficiencies, r t avid restrictins impsed by law r by the terms f the award. Further, ACP plicies regarding direct and indirect charges n NSF awards adhere t the guidelines in the NSF Award and Administratin Guide, Sectin V.D. (Current versin revised February 2014): A. Chapter V - Allwability f Csts Basic Cnsideratins Expenditures under NSF cst reimbursement grants are gverned by the Federal cst principles and must cnfrm with NSF plicies, grant special prvisins and grantee internal plicies. it is the grantee rganizatin that is ultimately respnsible fr ensuring that all csts charged t NSF awards meet the requirements f the applicable cst principles, grant general terms and cnditins, and any ther specific requirements f bth the award ntice and the applicable prgram slicitatin..