Policy Title Policy Number Version Contact Effective Date Approved By Cost Policies 312 DRAFT 0 Candy Shin, Chief Financial Officer Cost Policies Policy It is the goal of IRIS to cover the full costs of each individual sponsored project where permitted by the established policies of the funding agency. Purpose The purpose of this cost policy statement is to summarize the methods and procedures that this organization will use to allocate costs to various programs, grants, contracts and agreements. OMB Circular A-122, “Cost Principles for Non-Profit Organizations,” establishes the principles for determining costs of grants, contracts and other agreements with the Federal Government. Direct costs are those that can be identified specifically with a particular final cost objective. Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. IRIS policies for indirect costs are based on the multiple allocation base method described in OMB Circular A-122. The multiple allocation base method accumulates indirect costs into separate cost groupings, which are allocated to different functions by means of a base, which measures the relative degree of benefit. Only costs that are allowable, in accordance with the cost principles, will be allocated to benefiting programs. Scope Responsibilities Definitions Procedures 1 General Accounting Policies A. Basis of Accounting – Accrual Basis B. Fiscal Period – July 1 through June 30 C. All allowable direct costs are charged directly to programs, grants, activity, etc. D. Allowable direct costs that can be identified to more than one program are prorated individually as direct costs using a base most appropriate to the particular cost being prorated. E. Office Overhead Pools – IRIS office expenses are aggregated into two indirect cost pools which primarily benefit the programs whose personnel physically work at the two office locations. 1) Washington, DC Office Overhead – General expenses associated with the headquarters DC office are allocated to benefitting functions on the basis of the salaries and wages of personnel working at the DC office. Data Management Center (DMC) Office Overhead – General expenses associated with the Seattle, WA, data management center are allocated to benefitting functions on the basis of the salaries and wages of personnel working at the DMC offices. General & Administrative (G&A) Pool - All other allowable general and administrative costs (costs that benefit all programs and cannot be identified to a specific program) are allocated to programs, grants, etc. using a base that consists of total costs less equipment, participant support costs and subaward costs exceeding $25,000 per subaward per year. 2) F. 2 General Ledger Expense Accounts The IRIS General Ledger account code is a 7-character (non-award) or 11-character (award accounts) structure. 01xx-xxx Asset Accounts 02xx-xxx Liability Accounts 03xx-xxx Equity Accounts 04xx-xxx Revenue Accounts Fringe Benefits: 06xx-xxx Fringe Benefits expenses 0620-000 Pension - SEP/IRA 0630-000 Health Insurance 0640-000 Life Insurance 0645-000 Disability Insurance 0650-000 Parking 0655-000 Commuting 0660-000 Paid Time-Off (PTO) 0670-000 Education 0680-000 Misc. * * Benefits provided through a professional employer organization (PEO), such as Administaff, are expensed to the fringe benefits pool based on the allocation of service fees associated with the fringe benefits. Indirect Expenses: 07xx-A01 0710-A01 0715-A01 0720-A01 0725- A01 0726-A01 0727-A01 0728-A01 0750-A01 0755-A01 0756-A01 0760-A01 0770-A01 0780-A01 0781-A01 0782-A01 0783-A01 0784-A01 0785-A01 Washington, DC (Headquarters) Office Overhead pool expenses Salaries Fringe Benefits Computer equipment Equipment Leases Small equipment (other) Furniture Software Maintenance and Repair Consultant Services Professional Services Rent Office Supplies Internet Miscellaneous Postage Publications Shipping Telephone 3 07xx-A01 0786-A01 0787-A01 0788-A01 Washington, DC (Headquarters) Office Overhead pool expenses Temporary help Training Water 07xx-DMC 0710-DMC 0715-DMC 0720-DMC 0725-DMC 0726-DMC 0727-DMC 0728-DMC 0750-DMC 0755-DMC 0756-DMC 0760-DMC 0770-DMC 0780-DMC 0781-DMC 0782-DMC 0783-DMC 0784-DMC 0785-DMC 0786-DMC 0787-DMC 0788-DMC Seattle, WA (Data Management Center) Office Overhead pool expenses Salaries Fringe Benefits Computer equipment Equipment Leases Small equipment (other) Furniture Software Maintenance and Repair Consultant Services Professional Services Rent Office Supplies Internet Miscellaneous Postage Publications Shipping Telephone Temporary help Training Water 08xx-000 0810-000 0810-100 0815-000 0820-000 0826-000 0827-000 0828-000 0830-000 0831-000 0832-000 0833-000 0834-000 0835-000 0840-000 0850-000 General & Administrative (G&A) pool expenses Salaries Business Office Salaries Fringe Benefits Computer equipment Small equipment (other) Furniture Software Staff Travel – Domestic Staff Travel – Foreign Committee Travel - Domestic Committee Travel - Foreign Misc. Travel - Domestic Misc. Travel - Foreign Meetings & Conferences Maintenance and Repair 4 08xx-000 0855-000 0856-000 0857-000 0858-000 0865-000 0870-000 0880-000 0881-000 0882-000 0883-000 0884-000 0885-000 0886-000 0887-000 General & Administrative (G&A) pool expenses Consultant Services Professional Services Audit/Accounting Legal Services Insurance Office Supplies Communications Miscellaneous Printing Memberships/Subscriptions/Professional Activity Shipping Bank Fees Temporary help Training Unallowable Expenses: 0999-000 0999-000 0999-001 0999-002 0999-003 0999-004 0999-005 0999-006 0999-007 0999-099 0999-100 0999-102 Unallowable expenses Miscellaneous/other Promotional items Donations/Contributions Gifts (non-IRIS staff) Travel – misc. Penalties/Fines Alcohol Staff Lobbying Bank/investment fees Workshop/Entertainment/Social Activities 5 Award Expenses: XXXX - XXX - XX - XX a b - c - d Award Segment – Activity Segment – Suffix Code – Transaction Code a b. c. d. The first 4 numbers represent an award or funding source. The next 3 characters represent a task or program budget under the award (level at which expenditures are budgeted and tracked). The next 2 numbers (suffix code) represent an expense category. The last 2 characters (transaction code) represent an expense sub-category. Award Code XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Task Code Suffix Code XXX 39 XXX 40 XXX 43 XXX 44 XXX 45 XXX 46 XXX 47 XXX 48 XXX 49 XXX 50 XXX 51 XXX 52 XXX 53 XXX 54 XXX 55 XXX 56 Description Salaries Expense (HQ DC Office) Salaries Expense (non-HQ) Office Overhead Equipment Travel Participant Support Costs Materials & Supplies Publications & Printing Consultant Services Subawards Subawards Subawards Subawards <inactive> Misc. Subawards Other Direct Costs Allocation of Costs A. Compensation for Personal Services - Employee salaries are either charged directly to an award or are charged to an indirect cost pool, based on whether the function performed by the employee benefits a particular program (direct charged) or whether it has more general benefit to all programs and the organization as a whole. All compensation charges are supported by monthly or weekly (non-exempt) employee timesheets, which reflect the total time worked by each employee, and allocation of that time to specific awards, where appropriate, or to the applicable indirect cost pool. Supervisors review and approve employee timesheets. IRIS maintains auditable labor distribution records that reflect the actual activities of employees to support direct and indirect charges. 6 Direct Costs – Most IRIS employees’ salaries are charged directly to awards, particularly those employees who are dedicated to a particular project. Indirect Costs – Where employees’ work cannot be specifically allocated to a given grant or award, salary expenses are charged indirectly. The following employees charge 100% of their salary costs indirectly to the office overhead pools: o Data Management Center (DMC) Office Manager o Headquarters (DC) Office Manager The following employees charge 100% of their salary costs indirectly to the G&A pool: o President o Executive Assistant o Director of Planning o Director of Program Support and Special Projects o Financial Services staff o Sponsored Projects Office staff o Human Resources staff The following employees may charge their salary costs to both direct and indirect activities: o Meeting Planner o Media & Graphics Specialist o Web Developer o Public Outreach Manager B. Fringe Benefits – Fringe benefits expenses are budgeted and expensed as a percentage of actual salary or wage expenses. The fringe benefits pool includes: 1. payroll taxes (FICA)* 2. unemployment insurance* 3. workers compensation* 4. retirement plan 5. health insurance* 6. life insurance* 7. disability insurance* 8. parking/commuting 9. education/tuition reimbursement* 10. accrued paid-time off 11. employee recognition program 12. other – as may be approved by management and the benefits committee * Benefits provided through a professional employer organization (PEO) are expensed to the fringe benefits pool based on the allocation of service fees 7 associated with the fringe benefits. Release time costs (paid-time off (PTO), holiday pay, etc.) are included in salaries expense. PTO leave earned but not used during each fiscal period is accrued at fiscal year-end in the fringe benefits pool. The employee recognition program provides gifts to employees for years of service, at five, ten, fifteen, twenty, and twenty-five year milestones. The costs of such gifts (e.g., tangible non-cash gifts, gift certificates) are included in the fringe benefits pool. C. Board Expenses – Expenses for Board of Directors' travel and meetings are charged as indirect costs in the G&A pool. D. Travel Costs - Allocated based on purpose of travel. Travel costs (local and outof-town) may be charged as either direct or indirect costs depending on the purpose of the trip and/or the functional designation of the traveler. For example, travel of the IRIS management or business office staff is charged as indirect costs. Travel of direct-charge personnel to perform a specific task for an award would be considered a direct cost. E. Participant Support Costs – Direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia or training projects. 1. Costs must be budgeted as participant support in the program or activity budget specifically for the purpose of supporting the cost of attendance at these events. 2. Travel expenses specifically identifiable for staff, consultants and/or other participants who are receiving compensation (directly or indirectly) from IRIS will be charged as travel expenses and not participant support. 3. Participant support costs may include general catering expenses for workshops and meetings where meals and break refreshments are provided to everyone, even though some participants' meals might normally be charged as travel expenses. 4. Participant support does not include general meeting expenses, such as room and audiovisual rentals or facility internet expenses. F. Professional Services Costs (such as consultants, software development and legal services) - Allocated to the program benefiting from the service. Professional service costs are charged directly to the program for which the service was incurred. Costs that benefit all programs or are not identifiable to specific direct programs will be allocated to G&A. 1. The cost of the annual audit is charged indirectly. 2. Legal fees incurred specifically for a (direct or indirect) program or activity are charged to the program or activity that benefits from the service. 8 G. Occupancy/Rent – IRIS office lease expenses (Washington, DC and Seattle, WA), including utilities, are charged indirectly to an office overhead pool. The cost of other space and temporary rentals will be allocated to the program benefiting from the space. H. Office Expense and Supplies (including office supplies and postage) - Allocated based on usage. Expenses used for a specific program will be charged directly to that program. Postage expenses are charged directly to programs to the extent possible. Office supplies and postage purchased for general office use will be allocated to an office overhead pool. I. Equipment – Equipment consists of all tangible nonexpendable personal property with a unit cost of $5,000 or more and a minimum life expectancy of more than one year. The cost of equipment includes the purchase price, transportation costs, installation costs and other direct costs of readying for use. As NSF retains title to equipment purchased under the cooperative agreements, IRIS expenses equipment in the period purchased, charged directly to the programs authorized for such charges. No equipment item is charged indirectly. Items below $5,000 are reflected in the supplies category and expensed in the current year. J. Printing - Expenses are charged directly to programs that benefit from the service. Expenses that relate to IRIS activities in general that cannot be identified to a specific program will be charged to G&A. K. Insurance - Insurance needed for a particular program is charged directly to the program requiring the coverage. Corporate and other organizational insurance coverage that benefits all programs is allocated to G&A. L. Telephone/Communications – Office local and long-distance telephone expenses are charged to the office overhead pool. Communication expenses that relate to IRIS activities in general that cannot be identified to a specific program will be charged to G&A. Other communication expenses are charged to programs if readily identifiable. M. Training/Conferences/Seminars – Allocated to the program or activity benefiting from the training, conferences or seminars. N. Other Costs (including dues, licenses, fees, etc.) - Other costs will be allocated to the program or activity incurring the expense. Expenses that relate to IRIS activities in general that cannot be identified to a specific program will be charged to G&A. O. Unallowable Costs – IRIS recognizes costs that are unallowable in accordance with OMB Circular A-122, including alcoholic beverages, bad debts, advertising (other than help-wanted ads), contributions, entertainment, fines and penalties, lobbying and fundraising costs, may not be charged to Federal awards. Unallowable expenses are charged to IRIS unrestricted funds. 9