Why is there heavy scrutiny when charging items on sponsored projects?
As a recipient of federal awards, the University of Alabama at Birmingham is obligated to comply with a number of rules and regulations produced by federal agencies. Those agencies include the Office of Management and Budget (OMB) and the Cost Accounting Standards Board (CASB) which outline broad policies governing sponsored project financial administration as well as numerous individual agencies that award sponsored projects, such as the Public Health Service (PHS) and the National Science Foundation (NSF), which have their own agency-specific regulations for administrating sponsored awards. The CNR works in coordination with the appropriate UAB departments to ensure regulation compliance.
It is the responsibility of individual investigators, department staff, and other UAB administrators to understand and follow these regulations.
Simply stated, we have a professional and ethical responsibility to follow UAB cost accounting standards, Federal award regulations, and/or the terms and conditions of an award concerning the allocation or reallocation of budgeted funds.
Specifically, “Federal regulations (OMB Circular A-21 and the Federal Cost Accounting Standards) require that the same type of costs be treated consistently as direct (specifically identified to a particular project) or indirect (incurred for a common or joint purpose) costs.” See full text of the direct and indirect costs policy at: UAB Direct and Indirect Costs Policy
- Typical direct cost examples: salaries and wages, fringe benefits, travel, consultants, materials and supplies, and other expenses (project-related).
- Typical indirect cost examples: admin/clerical salaries/ wages and fringe benefits (Deans, departmental support personnel), office supplies, postage, shipping, laptops/iPads/computers, memberships, local phone service, etc.
There are exceptions to the above general rule, but these are handled on a case-by-case basis and should have been identified at the proposal development stage so that the appropriate paperwork can be submitted in advance of the award. The CNR facilitates these types of exceptions. During the proposal development phase, the Principal Investigator/Project Director should have a clear mathematical picture (budget) of their research strategy or program objectives.
Tip: Often, it is better to prepare your draft project budget well in advance of finalizing your narrative. You will find it easier to finalize your budget and make appropriate changes based on your project timeline, feedback from internal reviews, shifts in aims or objectives, etc.
Most sponsors offer some latitude in rebudgeting costs that may or may not require sponsor prior approval. Every cost must be allowable, allocable, reasonable, consistently treated and not restricted by sponsor agreement. Each project is NOT exactly alike. There are “gray” areas in post award management and all expenditures must benefit the project and be needed to accomplish the sponsor approved aims or objectives (scope of work).
You should spend as you propose!
The Center for Nursing Research (CNR) staff provides facilitation, guidance, and approval for costs related to sponsored projects.
Charging a sponsored project
- Complete or obtain preliminary documentation such as Goldenrods for travel, Pre-Event Approval for UAB sponsored events, PSF for FFS agreement, contracts, etc. well in advance to ensure ample time to process the requisition
- Locate the expenditure item in the budget
- Locate the correct object code (see Object Code Search)
- Create the Oracle entry (disbursement request, requisitions, PO, etc.)
- Print a copy of the requisition and attach back-up documentation such as conference info, exhibit info, quote
- Obtain appropriate CNR approval signature
- Expenditures $2,500 or less please contact Kevin Keane
- Expenditures over $2,500 please contact Frank Wiser
- CNR submits to School Fiscal Officer for final Oracle approval
Tip: This process allows the CNR staff to review the approved budget, check for proper object code usage, and provide guidance or feedback.
Tip: If you are charging an item not located in the approved budget or budget justification, you should check with the CNR staff in advance to ensure the item is allowed or paperwork that needs to be filed is completed. This step will make you proficient, efficient, and save a lot of time.
For more information contact Frank Wiser at firstname.lastname@example.org