CAN I CHARGE THIS ITEM TO A
GRANT?
Discussion of Potentially Unallowable Account
Codes
OPAFS Forum
January 19, 2016
OPAFS UPDATES/REMINDERS
Updates:
– Overdraft cleanup
• Report to CFO
• New Journal Voucher to move to
discretionary
– Campus Training Tool
– Financial Expense Report (FER) automation
update
Reminders:
– FER due Wed after monthly ledger cutoff
– Award Document Lookup Tool
– SPARCM invoices available to dept
STREAMLINED TRAINING AND RESOURCE TOOL (START)
Allowability
FACTORS AFFECTING ALLOWABLE COSTS
E CFR 200.403
• Allowable
• Reasonable
• Allocable
• Consistent Treatment
COSTS THAT
ARE NORMALLY
CONSIDERED
UNALLOWABLE
ON FEDERAL
AWARDS
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Advertising and public relations
Alcoholic beverages
Convocations or other events related to instruction
Donations
Entertainment
Fines and penalties
Fully depreciated assets or assets gifted by the federal
government
General purpose equipment, buildings, and land
Honoraria
Housing and personal living expenses
Insurance and indemnification
Legal costs
Lobbying
Memberships in any civic or community organization
Royalties or patents
NIH GRANTS
POLICY
STATEMENT
“The fact that a cost requested in a
budget is awarded, as requested, does
not ensure a determination of
allowability. The organization is
responsible for presenting costs
consistently and must not include costs
associated with their F&A rate as direct
costs.”
ALLOWABLE OR
UNALLOWABLE?
It Depends…
You Decide…
OPAFS
• Not the police
• Goal is to protect the PI and the department
in case of audit
• Want to review and spot check the award
• Currently, review at final report time (FER)
• Review for materiality
E CODES
/USUALLY
UNALLOWABLE
• Account codes that are pre-identified as
unallowable on federal awards
• OPAFS assigns at time of fund setup
• Validates transactions and blocks
unallowable transactions from posting
to a fund
• BLINK page
W CODES
/POTENTIALLY
UNALLOWABLE
Potentially unallowable expense
Not all inclusive
Award terms always trump this list
Updated list on BLINK
This is guidance, not black and white
Allows expenses to post to the fund at
point of entry but will attach a warning tag
• Recommend setting W codes
• Departments are responsible for assigning
W codes to a specific index
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FUTURE
TOOLS TO
HELP AHEAD
OF TIME
• Future work is to create a template in
Financiallink to help identify
questionable account codes before final
report
• Automated reminders with FER rollout
future phases
USEFUL LINKS
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OMB Uniform Guidance (UG)* E CFR 200.403 - Factors Affecting Allowability of Costs
https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniformadministrative-requirements-cost-principles-and-audit-requirements-for-federalawards#sec-200-403
OMB Circular A-21 Section C Basic Consideration
http://www.whitehouse.gov/omb/circulars_a021_2004#c
OMB Circular A-21, Section J: Selected items of cost
http://www.whitehouse.gov/omb/circulars_a021_2004/#j
NIH GPS, 7.9.1, Select items of cost - - presents specific items that may or may not be
included in the cost portion of grants.
http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch7.htm#selected_cost_i
tems
NIH Notice of Change to Non-Allowable Costs for PA-10-071: NIH Support for
Conferences and Scientific Meetings (Parent R13/U13)
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-12-048.html
Blink: OMB Uniform Guidance*
http://blink.ucsd.edu/research/policies-compliance-ethics/uniformguidance/index.html
Blink: E Account Codes (Usually Unallowable)
http://blink.ucsd.edu/finance/awards/managing/index-fund/code/e.html
Blink: W Account Codes (May Be Questionable)
http://blink.ucsd.edu/finance/awards/managing/index-fund/code/w.html
Blink: Sponsored Project Allowable and Unallowable Costs
http://blink.ucsd.edu/finance/awards/compliance/allowable.html
Blink: Travel and Entertainment Restrictions
http://blink.ucsd.edu/travel/entertainment/approval/restrictions.html
Blink: Exceptions to Coach and Economy Class Airfare
http://blink.ucsd.edu/travel/training-guidelines/booking/air/businessfirstclass.html
*OMB Uniform Guidance (UG) - effective Dec 26, 2014