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Federal Awards OMB Circular A-21, entitled “Cost Principles for Educational Institutions”, is the primary document which sets forth federal requirements related to charges to grants and contracts. This document provides guidance on direct charges to sponsored projects as well as the calculation and application of the indirect cost rate (now referred to as Facilities and Administration, or “F&A”). http://www.whitehouse.gov/omb/circulars/a021/a021.html OMB Circular A-110, entitled “Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations”, establishes the principles by which a federal agency must conduct business with non-profit institutions, including pre-award and post-award requirements, property, procurement and other standards for financial management systems. Various Policy Statements issued by individual agencies, like the NIH and PHS Grants Policy Statements: And the NSF Grant Policy Manual: http://www.nsf.gov/pubs/manuals/gpm05_131/index.jsp (Terms and conditions included on the grant award or contract document.)
There are a multitude of local government as well as voluntary agencies that award grants and contracts to the University. Each of those agencies has their own rules governing the use of those awards. Many of those documents are available from Columbia’s Office of Research Administration. http://www.columbia.edu/cu/researchadministration/index.html
University Policies All of the University’s policies governing expenditures also apply to grants and contracts. These policies include those related to procurement, human resources, accounts payable and payroll. Additionally, the Controller’s Office has developed a number of policies specific to grants and contracts. These policies include guidance on what costs may not be charged to sponsored projects. OMB Circular A-21 contains specific language which precludes or limits charging certain expenses to federal grants and contracts. These expenses include specifically unallowable costs, clerical and administrative salaries, and office supplies. Specifically unallowable costs include the following expenses, which may never be charged either directly or indirectly to a Federal grant or contract:
Consult Controller’s Office Policy Statement 92-1, Subcodes for Segregation of "Unallowable" Expenses, for a detailed explanation and listing. These can be found in the University Administrative Policy Library. Clerical and administrative salaries generally may not be charged directly to grants and contracts. There are important exceptions to this rule. Consult Controller’s Office Policy Statement 92-3, Charging Administrative and Clerical Salaries to Federal Grants and Contracts, for detailed explanation and institutional policy. Office expenses, such as postage, office supplies and local telephone calls, generally may not be directly charged to grants and contracts. There are important exceptions to this rule. Consult Controller’s Office Policy Statement 92-4, Charging Office Supplies and Other Administrative Expenses (other than salaries) to Federal Awards, for further information. Gifts (i.e. NOT grants) For internal parties interested in more information about CU Gift Policies, go to UDARNet at http://wwwb.ais.columbia.edu/udarnet/index2.jsp and Log in, Click on "Policies, Procedures and Best Practices", select "Gift Systems Policies" which will take you to an index of topics. For determining whether funding should be considered a gift or a grant, contact Research Administration.
Links to the various Columbia University policies are provided below:
Charging Administrative and Clerical Salaries to Federal Grants and Contracts Charging Office Supplies and Other Administrative Expenses to Federal Grants and Contracts Compliance with Federal Cost Accounting Standards Distinguishing Gifts from Sponsored Projects Financial Reporting and Closeout of Grants and Contracts International Research and Service Projects: Risk Management Procedures Management and Accounting for Moveable Capital Equipment Monitoring and Reconciling Sponsored Project Accounts Overdrafts on Sponsored Project Accounts Principal Investigator Responsibilities for Financial Oversight of Grants and Contracts Responsibility for Negotiation of Facilities and Administration and Fringe Benefit Rates Service Centers and Recharge Centers
Subcodes for Segregation of Unallowable Expenses Treatment of Program Income on Sponsored Project Accounts
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