Cost Policy Training Sponsored Project Training Program April 30, 2012 Beverly Blakeney & Jennifer Gagnon April 30, 2012 Sponsored Project Training Program 1 Learning Objectives Participants will review key concepts from March cost policy training Participants will learn important processes to enable the direct charging of normally indirect costs (F&A) Participants will learn key implementation tools Participants will become aware of available resources Participants will review important implementation dates April 30, 2012 Sponsored Project Training Program 2 What is the cost policy? It provides guidance, using Four Cost Principles, for directly charging costs. It clarifies what are normally direct costs and indirect costs (F&A). It defines what is meant by “unlike circumstances.” It sets out criteria for reasonable methods for allocating direct costs across more than one project. It describes a clear process and circumstances for charging indirect costs as a direct cost. April 30, 2012 Sponsored Project Training Program 3 What is an unlike circumstance? Activity or use of a cost item which is substantially greater in amount or different in purpose than the normal use April 30, 2012 Sponsored Project Training Program 4 Unlike Circumstances Criteria The sponsored agreement has an extraordinary need for the item or service that is beyond the level of services normally provided by departmental administration. The cost can be specifically identified to the work conducted under the sponsored agreement and is appropriately documented. The cost is allowable within the context of the University’s cost accounting standards. April 30, 2012 Sponsored Project Training Program 5 What is an allocation method? If a cost benefits two or more projects/activities in proportions that can be determined without undue effort or cost, the cost should be charged to the projects/activities based on the proportional benefit. If proportions cannot be determined due to the interrelationship of the work, then costs may be charged on any reasonable basis. April 30, 2012 Sponsored Project Training Program 6 Allocation Methods Examples of acceptable methods: Usage based – the cost of lab supplies is allocated to each sponsored agreement based on quantity used Time based – the cost of scientific equipment is allocated to each sponsored agreement based on number of hours used for each April 30, 2012 Sponsored Project Training Program 7 Allocation Methods Examples of unacceptable methods: “Spending down” Rotating charges without establishing relative benefit See http://www.uvm.edu/~cntrllrs/cas/Allocation_Examples.pdf for additional examples April 30, 2012 Sponsored Project Training Program 8 What’s up next Expense categories Decision points Key questions Justification form Process PeopleSoft changes Resources April 30, 2012 Sponsored Project Training Program 9 Expense categories requiring justification Administrative & clerical salaries General supplies & services Computer supplies & services Utilities Memberships & subscriptions Equipment maintenance Work Orders Telephone and telecommunications services April 30, 2012 Sponsored Project Training Program 10 Decision Points Does PI wish to direct charge items that are typically considered indirect? Is proposal to federal sponsor or for a federal subaward? Does proposal have an Extension or Experiment Station purpose? April 30, 2012 Sponsored Project Training Program 11 Key Questions 1. Because all projects require a certain amount of account reconciliation, correspondence, phone calling, office supplies, etc., how will the proposed charge(s) differ from the standard level of support expected for all projects? 2. How will the nature of the work differ from departmental administrative work conducted for all projects, and why are the charges necessary to conduct the work of the award? 3. The cost category (e.g., office supplies) may imply that the items are being used for administrative purposes. How will these items be used to conduct the specific work of the project, and what is their relevance to the methods used in conducting the project? April 30, 2012 Sponsored Project Training Program 12 Key Questions 4. How will the proposed charges be accurately documented and assigned to the project with a high degree of accuracy? For example, an administrator who is working on five or more projects including normal department administration work will be difficult to document accurately the relative benefit to any specific project. 5. How does the charge meet a specific need of the project and what is the derived benefit? April 30, 2012 Sponsored Project Training Program 13 Justification Form Clearly identifies the “unlike circumstances” Part of routing form & on SPA website Required for any federal or federal subaward in order to direct charge an expense that is typically considered an indirect charge ◦ Excluding Experiment Station, Extension, and Federal Formula Fund proposals April 30, 2012 Sponsored Project Training Program 14 Proposal Process Pilot in May 2012 Effective June 1, 2012 April 30, 2012 Sponsored Project Training Program 15 What should a PI do if they want to direct charge items that are typically indirect at the time of proposal submission? Yes or Unknown Yes Is this extension or experiment station Is it a federal funding source? No No form necessary but budgeted expenses must follow sponsor and university rules. No PI must complete justification form and include as many details as possible about the costs in budget justification. No form necessary but budgeted expenses must follow sponsor and university rules. SPA will review justification form and budget justification for completeness, accuracy, and appropriateness. Approved? Yes Proceed with proposal submission Remove references to direct charging of indirect costs from budget narrative prior to proposal submission April 30, 2012 Sponsored Project Training Program 16 After Award Acceptance Effective June 1 for award process Effective July 1 for expenses April 30, 2012 Sponsored Project Training Program 17 What should a PI do if he/she wants to direct charge items that are typically indirect when an award is processed (for proposals submitted prior to May 1)? Is it a federal funding source? Yes Is this extension or experiment station No No form necessary but budgeted expenses must follow sponsor and university rules. PI must complete justification form. Yes No form necessary but budgeted expenses must follow sponsor and university rules. SPA will review justification form for completeness, accuracy, and appropriateness. Approved? Yes SPA will enter approved admin salaries in PS project team page & create appropriate F levels after July 1 so charging of the requested items can occur. Direct charging of requested items is not allowed. April 30, 2012 Sponsored Project Training Program 18 What should a PI do if they want to direct charge items that are typically indirect after award acceptance? Is it a federal funding source? Yes Is this extension or experiment station No No form necessary but budgeted expenses must follow sponsor and university rules. PI must complete justification form. Yes No form necessary but budgeted expenses must follow sponsor and university rules. SPA will review justification form for completeness, accuracy, and appropriateness. Approved? Yes SPA will enter approved admin salaries in PS project team page & create appropriate F levels so charging of the requested items can occur. Direct charging of requested items is not allowed. April 30, 2012 Sponsored Project Training Program 19 Process for non-federal awards Cost principles apply Sponsor guidelines and university policy must be followed Justification form is not required to direct charge costs that are typically considered indirect April 30, 2012 Sponsored Project Training Program 20 Other Implementation Tool: PeopleSoft Project team page, DA DC role ◦ Grants > Awards > Project April 30, 2012 Sponsored Project Training Program 21 PeopleSoft ◦ New budget accounts (F level), effective 7/1/2012 General supplies & services Agricultural supplies & services Lab & research supplies Utilities Memberships & subscriptions Work orders Telephones & telecommunications services ◦ Expense account changes, effective 7/1/2012 April 30, 2012 Sponsored Project Training Program 22 PeopleSoft The following expense types are typically charged as an indirect cost to sponsored projects but in unlike circumstances, may be direct charged. These expense categories correspond with F level budget accounts and will be set up on an as-needed, award-specific basis for federal and federal flow through awards after all steps of the cost policy justification process taken place: General supplies & services Computer supplies & services Utilities Memberships & subscriptions Equipment maintenance Work Orders Telephone and telecommunications services April 30, 2012 Sponsored Project Training Program 23 Key Dates May 1 ◦ Pilot for proposals June 1 ◦ Proposals will start using new form to justify budgeting normally classified indirect costs as direct costs July 1 ◦ Policy goes into effect ◦ Key date for expenses ◦ PeopleSoft account changes April 30, 2012 Sponsored Project Training Program 24 Reference materials & resources Available now! ◦ Cost Accounting Services web site: http://www.uvm.edu/~cntrllrs/cas/ Direct cost allocation examples Additional details about direct vs. F&A costs and unlike circumstances Cost policy FAQs ◦ Justification form ◦ Invite SPA & CAS to faculty meetings to help spread the word April 30, 2012 Sponsored Project Training Program 25 Reference materials & resources Coming soon ◦ Matrix of PeopleSoft budget & account changes ◦ Closeout report changes – project team page information ◦ List of administrative/clerical job titles ◦ Memo to faculty members April 30, 2012 Sponsored Project Training Program 26 Questions? April 30, 2012 Sponsored Project Training Program 27 Learning Objectives Participants will review key concepts from March cost policy training Participants will learn important processes to enable the direct charging of normally indirect costs (F&A) Participants will learn key implementation tools Participants will become aware of available resources Participants will review important implementation dates April 30, 2012 Sponsored Project Training Program 28