I. Purpose
The purpose of this policy is to ensure that The College of St. Scholastica (CSS) will be compliant with the provisions of the Federal Office of Management and Budget’s regulations, including 2 CFR 200, Uniform Guidance. It provides direction to faculty and staff regarding the allowability of costs that can be charged to Federal grant awards.
II. Policy
The College of St. Scholastica will follow 2 CFR 200 – Subpart E, applicable agency regulation, program guidelines, and award terms and conditions when determining allowability of costs. For a cost to be charged to a federal grant, it must be allowable, allocable, reasonable, and consistent.
The authority to determine the allowability of costs rests with the CSS finance department. Only costs that are allowable under general CSS policies are allowable for federal grants.
All transactions must be authorized by the relevant Principal Investigator or Project Director (PI/PD). The PI/PD is also responsible for collecting and maintaining any necessary supporting documentation. The PI/PD’s department is responsible for paying for any expenses determined to be unallowable after they have been incurred.
Items which are part of CSS’s indirect cost pool may not also be charged as direct costs. Cost sharing requirements may only be met by cost items that meet the definition of direct costs and are not included in the CSS indirect cost pool.
III. Definitions
Allowable – Allowable costs must be necessary for the performance of the award, follow all provisions in the federal award, be treated consistently, be determined in accordance with generally accepted accounting principles, not included as a cost share ore match on another federal award, and be appropriately documented.
Allocable – Allocable costs are costs which can directly be assigned to a federal award because it specifically supports the federal award. Costs incurred that support both a federal award directly and another grant or CSS must be split according to the benefit received to be allocable.
Reasonable – A cost is reasonable if it does not exceed the cost which would be incurred by a prudent person under the circumstances at the time the decision was made to incur the cost. Reasonable costs are necessary for the performance of the award, align with market prices for similar goods and services, and follow establish CSS practices and procedures.
Consistent – A cost is consistent if it receives the same treatment (direct or indirect) across awards, and follows CSS policies and procedures.
IV. Roles and Responsibilities
Principal Investigator/Project Director – Authorize all grant expenses and ensure allowability of costs prior to authorizing expenses. Responsible for providing all necessary supporting documentation to verify allowability. Authorization responsibilities may not be delegated but documentation responsibilities may be delegated to another individual.
Grant Accountant – Review all grant expenses and confirm allowability of costs prior to seeking reimbursement of expenditures, investigate expenses with insufficient documentation, take corrective action if needed, communicate all instances of corrective action to the respective PI/PD.
Grants Management Specialist – Can provide non-binding advise to PI/PDs, assists the Grant Accountant in researching challenging cost items, notifies the PI/PD and Grant Accountant of any cost-related grant terms.
Controller – Determines final course of action for any expenses if the PI/PD and Grant Accountant disagree regarding allowability.