cost sharing v3.ppt - university of california, davis · cost sharing tracking system web site 3...

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Effort Commitments and Cost Sharing

Presented by: Contracts and Grants

Accounting

Debra Henn

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Effort Commitment and Cost Share Policy and Guidance

Uniform Guidance 2 CFR 200 – replaces:– OMB Circular A-110– OMB Circular A-21

UCD Policy & Procedure Manual 330-31 -replaces– UC Davis Directive 06-049

Effort Commitment System web site Cost Sharing Tracking System web site

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Effort Commitment and Cost Share Tracking Systems

Developed to ensure University is in compliance with Federal regulations

Strictly “tracking” systems, not “financial” systems—information entered does not affect data on the General Ledger (GL)

Used to track and document binding obligations of effort and cost share commitments

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Benefits of EC & CSTS Systems:

Reduce paperwork Provide monitoring tools for compliance Track information on cost sharing for effort

reporting certification Verifiable documentation supports audit trail Produce Cost Share Contribution Report as

needed Provide necessary information for F&A rate

proposal development

Who is responsible?

The department that administers the contract or grant is responsible for -– entering the data in the Effort Commitment

System and the Cost Share Tracking System – for communicating with any other departments

involved in the project to ensure that they have the necessary UC fund and account information

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Topics in this Session

What is an effort commitment? Exercise 1: Calculating effort commitments Using the Effort Commitment system What is cost sharing? Using the Cost Share Tracking System Exercise 2: Cost Sharing and CSTS Best Practices

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Effort Commitments

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What is an effort commitment?

Effort commitment is the portion of time committed to a particular activity expressed as a percentage of the individual's total activity for the institution.

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Effort Commitment Examples

PI submits a proposal for a one-year award and commits 1 summer month; sponsor pays 1 month salary + benefits

PI submits a proposal for a one-year award and commits 1 month during the academic year; no PI salary is indicated in the budget

PI submits a proposal for a three-year award and commits 5% time; sponsor pays $5,000 per year toward salary + benefits

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Tracking Effort Commitments

When the University commits effort to a sponsored project, the percentage of effort committed must be tracked

UC Davis requires us to track at least a minimum level of effort by the PI on every federal research project (PPM 330-31)

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Effort Commitment Versus Effort Report

An Effort Commitment is a promise we make to a sponsor in the award contract that an individual will work on the project for a specified portion of his/her time

An Effort Report is an after-the-fact certification that shows we met the effort commitment to the sponsor

Calculating Effort Commitments

Look at the award documents for commitments of effort – Look in narrative and budget– Look for a quantifiable amount of effort:

percentage of effort, number of days-weeks-months, salary dollars, etc.

Convert the effort to a percentage Enter the amount in the Effort Commitment

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How to Calculate Effort

Effort % = total time worked on the project divided by total time worked for UC Davis

Examples: – PI with a 9-month appointment works on the

project for 2 months during the academic year; effort is 2/9 or 22%

– PI with a 9-month appointment works on the project for 1 month during the academic year plus 1 summer month with additional compensation; effort is 2/10 or 20% 14

Minimum Effort for the PI

PPM 330-31– All federal research awards require some level of

committed PI effort– A reasonable amount of PI effort must be directly

charged or cost shared The PI decides what is reasonable

– The University encourages direct charging

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Minimum Effort for the PI

If no quantifiable amount of effort for the PI is stated in the award documents and the award is federally funded and the higher education function on at least one account is organized research, then some amount must be committed – 1-2% minimum is no longer in effect

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Direct Charge Versus Cost Share

Once the effort commitment percentage is known, determine how that effort will be paid– Direct Charge if the salary will be paid entirely by

the sponsor– Cost Share if the salary will be paid entirely by the

University (or by a third party). – If only part of the salary will be paid by the sponsor,

enter two lines and indicate the portion to be direct charged and the portion to be cost shared

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Effort Commitment Exercises

See page 23 of handout for Effort Commitment Calculation exercises

Work on effort calculations (5-10 minutes) Discuss answers (10 minutes)

Effort Commitment System

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Use the Effort Commitment system to verify and maintain effort commitments– Departments are responsible for effort commitment

data– CGA will enter initial PI effort commitments based on

the Data Sheet from Sponsored Programs if received– Departments must verify the commitments entered by

CGA and make any necessary corrections or additional entries, as well as maintain the commitments during the life of the award

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Online system accessible with UCD campus login ID and Kerberos password

FIS Web Applications link in DecisionSupport (DS) or athttps://accounting.ucdavis.edu/tp/extramural/effortcommitment/forms/effort_commitment.cfm

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Entering Effort Commitments

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On the Effort Commitment Maintenance query screen, enter the OP Fund, award expenditure account number, or PI name or ID

Use the date ranges to view only current effort commitments

Click Enter or View Commitments button

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Entering Effort Commitments

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Entering a commitment for an individual– Enter employee’s name or ID– Choose an appropriate role– Enter start and end dates that reflect the

commitment period. Break down effort by budget period ONLY when

necessary; average effort certified over the entire award must equal effort commitment

– When entering an account (optional), enter the expenditure account assigned to the OP Fund.

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Entering a commitment, cont’d – Enter the percentage of effort committed for the

selected date range Use the Effort Calculator for assistance in determining

the percentage of commitment

– Choose whether the effort will be direct charged (paid by the sponsor) or cost shared (paid by the University)

– Choose whether the commitment is awarded or pending (removed will cancel a commitment)

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Help with Calculations

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Effort Calculator

To help convert effort from days-weeks-months to percentages and calculate summer comp, use the effort calculator

The effort calculator is accessed by clicking on the button next to the effort percentage field on the effort commitment page

For more information on the calculator, refer to the Effort Commitment web site– http://afs.ucdavis.edu/systems/effort-commitment-

system/effort-calculator.html

DS-323 Report

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DS-323 Effort Commitments

About– Shows effort commitments as entered in the Effort

Commitments screen (FIS Web Applications)– Use to determine whether a PI is overcommitted– Run and review regularly to ensure that the data

is complete and correct and that PIs are not overcommitted

– Use to track PI current and pending projects

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Criteria– Always enter a date range, otherwise the report

will show all effort commitments including past and future

– Enter a DaFIS ID to view effort commitments for a particular PI

– Enter a UC Fund to see all effort commitments for a particular project

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Criteria– Enter a value in ‘Commitments Over Percent’ to

monitor faculty that may exceed the percentage allowed by the school/college

– Enter an organization code to run for a department

– Option to view only awarded, or include pending and removed entries

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Report– Legend in the header explains codes used to

indicate role, type, and status– Be careful when noting the totals as some

selection/sort options will double-count commitments and the totals will be incorrect

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Need 323 results here…

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Effort Commitment Best Practices

Enter effort commitments for PIs and key personnel (mainly faculty)

When a new award is executed, use the DS-323 to review the total committed effort for each individual to avoid over-commitment

Use the date range filters to view only effort commitments for the relevant time period

Do not delete effort commitments after the end date36

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Time for a break?

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Cost Sharing

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What is cost sharing?

Cost sharing or matching is that portion of project costs not paid by the Federal Government (or other primary sponsor)

Cost sharing is the part of the project that the University will fund

Third parties may also contribute goods or services to a project as cost sharing

Names for Cost Sharing

Cost share Matching funds In-kind Recipient contribution State share

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Cost Sharing Examples

Award A requires a piece of new equipment that costs $20,000. The budget indicates that the sponsor will pay up to $10,000 of the equipment costs. The University must pay the rest.

PI submits a proposal for a three-year award and commits 15% time; sponsor pays $5,000 per year toward salary + benefits.

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How does the data tie together?

Effort commitments are designated as direct charge or cost share

Direct charges are recorded in PPS

Cost share is recorded in CSTS

ERS uses data from PPS and CSTS to generate effort reports for certification

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Cost Sharing that Must Be Tracked

Mandatory effort and any other mandatory expenditures– Required by the sponsor as a condition of

obtaining an award– Must be included or the proposal will not be

approved by the sponsor

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Cost Sharing that Must Be Tracked, cont’d

Voluntary committed effort– Sponsor does not require an effort commitment

as a condition of award– Effort commitment is offered by the University– Effort is quantified in the proposal– Becomes a binding commitment – University must provide funds to fulfill the

sponsored agreement Other voluntary committed expenditures

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Cost Sharing that Should NotBe Tracked

Voluntary uncommitted effort– Not promised to sponsor– Effort over and above any commitments

Other voluntary expenditures– Miscellaneous expenses not included in budget

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Criteria for Contributions

Verifiable from recipient’s records; must be an expenditure on the ledger, not merely proposed

Not included as contributions for any other Federally assisted project or program (cannot be used twice)

Necessary and reasonable for accomplishment of program objectives

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Criteria for Contributions, cont’d

Allowable under the applicable cost principles (A-21 or UG)

Expended during the performance period Not paid by the Federal Government under

another award, except where authorized by Federal statute

Included in the approved budget when required by the Federal awarding agency

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Sources of Cost Sharing

University Funds Unrecovered F&A costs (with approval) Third-Party Contributions Other Sponsored Projects (Non-Federal) with

approval Indirect Cost Return funds Other unrestricted funds

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Costs that Can Be Cost Shared

Faculty, student, and/or staff effort expended in the performance of a sponsored agreement– Includes salary and benefits

Equipment acquired for the project Travel Expenses Laboratory Supplies F&A costs associated with the cost shared

direct costs

Costs that Can Be Cost Shared, cont’d

Unrecovered F&A costs may be included as part of cost sharing only with the prior approval of the Federal awarding agency– In this case, the expense cannot be tracked in

CSTS; the CGA Fund Manager will make the calculation and manually add the cost to the Contribution Report submitted by the department

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Costs that Can’t Be Cost Shared

Items normally treated as F&A costs– Department administration, space, utilities, library

resources, etc. Specific unallowable costs

– Meals, alcohol, entertainment, etc. Items already owned by the University (not

purchased during the project period) Items cost shared on other projects Amounts over the NIH salary cap 52

What is the University committing?

University funds will be provided to pay for time and expenses that benefit the sponsor’s project

Cost shared expenses will be documented Allowable costs will be timely and accurately

documented Expenditures for cost sharing will be certified Records for cost sharing will be retained for the

same period as the records for the related sponsored agreement

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Other facts about cost sharing

Once committed, cost sharing is a binding obligation

Cost sharing effort is included in the calculation of total committed effort

An individual cannot commit more effort than is reasonable in relation to his/her other institutional responsibilities

Other facts about cost sharing, cont’d

CSTS provides documentation for identification of cost shared direct costs when Facilities and Administration (F&A) proposals are prepared – Cost shared direct costs are included in the

Organized Research base, Other Sponsored Activities base, etc.

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Cost Share Tracking System

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Cost Share Tracking System (CSTS)

Online system accessible with UCD campus login ID and Kerberos password

FIS Web Applications link in DecisionSupport (DS) or at https://accounting.ucdavis.edu/tp/extramural/costsharing/

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Set Up Prior to Access

Contracts and Grants Accounting (CGA) sets up the UC fund and the KFS Award for an executed agreement and also makes a setup entry in CSTS

An automated e-mail is sent to the AccountManager and Principal Investigator on anyactive accounts for the fund

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Who can access expenses in CSTS?

The UC fund/award must have at least one active account (no expiration date)

User must have one of these roles on that account:– Fiscal officer (Account manager)– Account associate – Account delegate(s)

Process a KFS Account document to change the account manager or associate assigned to an account, or to remove the expiration date from the account

Process a KFS Delegate document to add or change the account delegate(s)

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Manage Cost Share Entries

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Manage Cost Share Entries, cont’d

Select the UC Fund from the drop-down menu Click on the appropriate link to add Salaries and

Wages, Equipment, Supplies/Travel, or Other When entering multiple lines on the Manage Cost

Share Entries screen be sure Description field entries are unique for each line– Don’t keep the same description, such as the

employee name, on each line– The descriptions are used on the Retroactive

Import and as group headers on the Contribution report

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Manage Cost Share Entries, cont’d

Only non-federally funded accounts can provide cost shared contributions in the Cost Share Tracking System

Any fields with red asterisks are required Cost shared expenses must be incurred

during the performance period

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Add Salaries and Wages

Imports payroll objects from labor ledger; Do NOT use this category for WOS employees (use 3rd party contribution)

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Add Equipment

Imports equipment objects under SUB4;

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Add Supplies/Travel

Imports supplies objects under SUB3 and travel objects under SUB5;

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Add Other KFS Expenses

Imports objects under SUB7, SUB9, SB73, SB74, SB09, and SCHL;Banner entries will import but only if posted to one of these object consol.

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Add 3rd Party Contributions

No import for these items, as there is no ledger expense associated with them – no cost to UC Davis

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Managing 3rd Party Contributions

Used for tracking contributions from entities outside of UC Davis, such as volunteer time, equipment, or supplies

Use for emeritus faculty time/effort or for others who are without salary (WOS)

Value of 3rd party contributions should be properly documented, preferably on the contributor’s letterhead, at the time the goods or services are provided

Documenting Third-Party Contributions

We need an official letter from the third party (on their letterhead) that identifies or describes:

– The project receiving the benefit – The type of cost share provided e.g. personnel time,

supplies, equipment, etc. For personnel time, a breakdown of names and time spent is desirable.

– The time period during which the items were provided– The basis of the valuation of the items. Items must be

valued at their value to the project.

Contribution letters must be after-the-fact; letters of intent or commitment are not sufficient.

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Documenting Third-Party Contributions, cont’d

For faculty or other employees who are without salary (WOS)

– Letterhead is not necessary, but– Calculations showing the value of the contribution should be

documented– For emeriti, the last or highest salary rate may be used– For other WOS employees, use a salary appropriate for the

type of effort provided.– The employee providing the effort must sign the document.– Otherwise, the document should meet the criteria as stated

on the previous slide.

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Retroactive Transaction Import

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If the award has already begun and expenses have been incurred, use the Retroactive Transaction Import to select the transactions from the beginning of the expenditure period through today

Do the retroactive import for EACH tracking entry

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Imported Transaction Review Retroactive Transaction Import

After running the query, look at the Imported Transaction Approval screen and decide whether each transaction is appropriate for cost sharing on this project and Approve or Reject accordingly

If none of the selected transactions should be cost shared click Reject all Transactions

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After Creating Cost Share Entries

If the award is new and no expenses have been incurred, or the Retroactive Transaction Import was used to select transactions through today, then the information in CSTS is current

An automatic import will occur nightly and will identify possible cost sharing transactions based on the information in the tracking entries

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After Creating Cost Share Entries

Once a month or so, departments should – Review the transactions in the Imported Transaction

Approval screen,– Decide whether each transaction is appropriate for

cost sharing, and – Approve or Reject accordingly

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Approved Transaction Review

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Approved Transactions Review

Review the approved transactions prior to printing a Contribution Report

Go to Approved Transaction Review to see a list of all approved transactions for cost sharing

The entries are separated into 2 categories: GL transactions and Payroll transactions;– click on KFS document numbers for more info on

a transaction

Contribution Report

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Contribution Report

Used to substantiate the amount reported to the sponsor and to show that cost sharing commitments were met– Summary report shows totals by tracking entry

(and reference # for GL expenses)– Detail report shows each approved transaction

Report must show at least the dollar value committed to the sponsor; it may not be possible to get the exact dollars

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Contribution Report (Summary) Contribution Report (Summary)

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Contribution Report (Detail) When the Award Ends

Print the Contribution Report if cost share was commited to the sponsor

Report must be certified by the PI and sent to CGA– Not necessary to have PI sign if cost share is for

minimum PI effort only (PPM 330-31) CGA closes cost sharing for the fund, making the

information in CSTS read-only Department expires expense account after the cost

share reporting is complete (removes fund from CSTS drop-down list)

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When the Award Ends

When the department expires all expenditure accounts for the fund, the fiscal officer/account manager, account associate and any account delegates can no longer view or select the fund in CSTS

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CSTS Process Summary

To start up a new award where no expenses have been incurred in PPS or KFS

1. Set up UC Fund and CSTS (CGA)2. Manage Cost Share Entries – set up items to be

cost shared

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To start up a new award where expenses have already been incurred in PPS or KFS

1. Set up OP Fund and CSTS (CGA)2. Manage Cost Share Entries – set up items to be

cost shared3. Retroactive Transaction Import – look for existing

transactions in PPS and KFS; do the retroactiveimport for EACH tracking entry

4. Imported Transaction Approval - approve or reject transactions for inclusion on the Contribution Report

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Monthly throughout the life of the award– Imported Transaction Approval - approve or reject

transactions for inclusion on the Contribution Report

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At the end of the award– Approved Transaction Review – final review of

approved transactions prior to generating report– Print the Contribution Report– Verify that cost share commitments have been

met– Have PI sign off on report unless commitment is

only for PI minimum effort

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CSTS Best Practices

When entering multiple lines on the Manage Cost Share Entries screen, be sure that the description field entries are different for each line – Don’t enter the same description such as just the

employee name– The descriptions are used on the Retroactive Import

and as group headers on the Contribution report

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CSTS Best Practices

When adding new entries on the Manage Cost Share Entries screen, consider whether a Retroactive Import is needed– Have any expenses related to this entry already

posted to PPS or KFS?

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CSTS Best Practices

Review and approve or reject cost share transactions monthly for effective management– Credits for transactions such as rebates should be

approved if the original purchase was approved– Be careful! Payroll transfers that move post-2011

expenses off the cost share account will not import, even if the original expense has been cost shared. Review cost shared payroll to ensure that expenses are still valid. (CGA checks for this before submitting cost share reports to sponsors.)

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CSTS Best Practices

Keep payroll records accurate and current Avoid frequent cost transfers; they can impact

cost share transactions– When cost transfers occur, the original expense

should be removed prior to reporting Expire KFS accounts that are no longer needed

– This removes the fund from the drop-down list– Don’t expire until the Contribution Report is final

DS-324 Report

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DS-324 Research Admin Discrepancies

About– Looks for inconsistencies in data across systems

and shows discrepancies Effort Commitment marked as Cost Share but no entries

in CSTS OP Funds marked as Cost Share but no entries in CSTS OP Funds with no Effort Commitment entries in EC

system

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About– Run and review the three reports regularly to

ensure that the data is complete; problems or discrepancies should be corrected as soon as possible Especially important in September/October prior to effort

report generation

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Criteria– Choose one or more of the discrepancy report types– Always enter a date range, otherwise the report will

review all sponsored awards including past and future– Enter a PI to review the projects for one faculty at a

time– Enter account manager to review all your projects– Enter an organization to review all projects for a

department

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Report– For each type of discrepancy report, there is an

explanation telling what caused the discrepancy and how to fix it

– Data in results is different for each of the three reports

– Click on the fund number to drill down to the OP Fund Detail report for more information about a project

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Report– Keep in mind that some discrepancies will not be

fixed; keep documentation showing the explanation Example: construction grants do not require PI minimum

effort

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Cost Sharing and CSTS Exercises

See page 25 of handout for Cost Sharing and CSTS exercises

Work on exercises (10-15 minutes) Discuss answers (15 minutes)

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Resources

Effort Commitment System– https://accounting.ucdavis.edu/tp/extramural/effortcommitm

ent/forms/effort_commitment.cfm Cost Share Tracking System

– https://accounting.ucdavis.edu/tp/extramural/costsharing/ Effort Commitment Help Web Site

– http://afs.ucdavis.edu/systems/effort-commitment-system/index.html

Cost Sharing Help Web Site– http://afs.ucdavis.edu/systems/cost-share-system/index.html

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Resources

Uniform Guidance– http://www.ecfr.gov/cgi-bin/text-

idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl

OMB Circular A-21 – http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

OMB Circular A-110– http://www.whitehouse.gov/omb/circulars/a110/a110.html

UCD Policy & Procedure Manual 330-31– http://manuals.ucdavis.edu/PPM/330/330-31.pdf

Resources for information on Effort Commitments and Cost Sharing Policy and Guidance

Uniform Guidance http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl OMB Circular A-110 http://www.whitehouse.gov/omb/circulars/a110/a110.html OMB Circular A-21 http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html Policy and Procedure Manual, Section 330-31 http://manuals.ucdavis.edu/PPM/330/330-31.pdf

Effort Commitments

Effort Commitment System https://accounting.ucdavis.edu/tp/extramural/effortcommitment/forms/effort_commitment.cfm

Effort Commitment Help http://afs.ucdavis.edu/systems/effort-commitment-system/index.html

Cost Sharing

Cost Share Tracking System https://accounting.ucdavis.edu/tp/extramural/costsharing/ Cost Sharing Help http://afs.ucdavis.edu/systems/cost-share-system/index.html

Other Contracts & Grants Accounting website http://afs.ucdavis.edu/our_services/contracts-e-grants/index.html

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http://www.whitehouse.gov/omb/circulars/a110/a110.html

http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

http://manuals.ucdavis.edu/ppm/330/330-31.htm

http://accounting.ucdavis.edu/costshare/index.cfm

http://directives.ucdavis.edu/2006/06-049.cfm

https://accounting.ucdavis.edu/tp/extramural/effortcommitment/forms/effort_commitment.cfm

https://accounting.ucdavis.edu/tp/extramural/effortcommitment/forms/effort_commitment.cfm

https://accounting.ucdavis.edu/tp/extramural/costsharing/

http://accounting.ucdavis.edu/EX/

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Effort Commitment Calculation Exercises

1. PI commits 15% effort for one year in the budget narrative of a sponsored research proposal. The PI salary is $100,000 per year including benefits. The proposal budget indicates $15,000 including benefits.

a. What is the effort commitment? b. Is the effort to be directly charged or cost shared?

2. PI does not indicate an effort commitment in the budget narrative for year one of

a sponsored research project. The proposal budget indicates $10,000 for PI salary including benefits.

a. Is there an effort commitment? b. Assume the PI salary including benefits is $100,000 per year. What is the

effort commitment? c. Is the effort to be directly charged or cost shared?

3. PI indicates a 25% commitment in the budget narrative and the budget shows

$5,000 including benefits for PI salary. The annual salary of the PI is $100,000 including benefits.


4. PI has a 9-month appointment and works 2 summer months. For the first budget

year on Project A, she commits 1 summer month with 100% to be charged to the grant.


5. PI has a 9-month appointment and works 1 summer month. For the first budget

year on Project B, he commits 1 month during the academic year at 50% plus 1 summer month at 100%. One 1 month salary and benefits will be charged to the grant.


6. PI has an 11-month appointment. She has a 25% effort commitment on a grant

and will only charge 1/11 summer salary to the grant. a. What is the % to be direct charged? b. What is the % to be cost shared?

7. PI has a 9-month appointment. He has a 25% effort commitment on a grant and

will only charge 1/9 summer salary to the grant. a. What is the % to be direct charged? b. What is the % to be cost shared?

8. PI has a 9 month appointment. She has a 25% effort commitment on a grant and

will only charge 2/9 summer salary on the grant. a. What is the % to be direct charged? b. What is the % to be cost shared?

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Cost Sharing Exercise Questions 1) Dr. Bernard’s new NIH project will use 50% of his existing laboratory space for the

duration of the project and does not include lab space costs in the proposal budget. a) Is this cost sharing? b) Why or why not?

2) Dr. Rice submits a research proposal to USDA without stating a commitment of

effort. a) Is this cost sharing? b) Why or why not?

3) A new scanning electron microscope is purchased with University funds as a

condition of Dr. Jameson’s NSF award. a) Is this cost sharing? b) Why or why not?

4) Dr. Singh proposes to spend 20% of his effort on a new NIH project, but he will

charge only 5% of his salary to the project. a) Is this cost sharing? b) Why or why not?

5) Dr. Ho is funded 60% on DOE Grant A and 40% on NSF Grant B. He receives a new

award that contains no commitment of effort to the sponsor. a) What is the problem? b) How is it resolved?

6) Dr. Wei committed 200 hours to his NASA project. He made a breakthrough in

March and spent about 50 additional unplanned hours on the development, which was within the project scope and benefited the project. a) Should this cost sharing be tracked in CSTS? b) Why or why not?

7) Dr. Adlington has an Army contract that is administered in Geology but his home

department is in Chemistry. Which department is responsible for entering any necessary effort commitment and cost share data?

8) When is a Retroactive Transaction Import necessary?

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9) When should Approved Transaction Review be performed? 10) How often is Imported Transaction Approval needed? 11) In Imported Transaction Approval, when should a transaction be

a) Approved?

b) Rejected? 12) What types of transactions appear in Imported Transaction Approval? (Where do the

transactions originate?) 13) When should a Contribution Report be generated and signed? 14) Who can access the data for a project in CSTS? 15) What is the most common reason a user can’t see their desired fund on the drop-down

list in CSTS?

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The Office of Management and Budget (OMB) has combined many federal circulars into a single guidance document (known as Uniform Guidance, or 2 CFR 200) that can be used by all agencies. These new regulations became effective December 26, 2014.

CHARGING ADMINISTRATIVE/CLERICAL AND PROGRAMMATIC SALARY COSTS Applicable Uniform Guidance (UG) Sections: 200.413

200.430

ADMINISTRATIVE AND CLERICAL SALARIES (IN CERTAIN CIRCUMSTANCES) AND PROGRAMMATIC SALARY COSTS CAN BE INCLUDED ON COMPETITIVE AND NON-COMPETITIVE PROPOSAL BUDGETS. Administrative and Clerical Salaries In general, administrative and clerical salaries should still not be direct charged, but the rules governing “major project or activity” exceptions have been dropped and replaced by the following criteria, all of which must be met: 1. Administrative or clerical services are integral* to a project or activity; 2. Individuals involved can be specifically identified with the project or activity; 3. Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and 4. The costs are not also recovered as indirect costs. If all of these requirements are met, PIs/departments should add a new justification statement to proposals to facilitate the required agency approval. *UC Davis has determined that integral means the services are essential, vital, or fundamental to the project or activity and we have sponsor approval for spending direct costs in this manner. Programmatic Salary Costs Costs related to protocol development and maintenance, managing substances/chemicals, managing and securing project‐specific data, and coordination of research subjects are allowable direct costs when they are “contributing and directly related to work under an agreement.” Thus, these programmatic costs may be direct charged using the same underlying requirements as other types of direct costs, and are not subject to the extra approval requirements required of administrative and clerical costs. They are still subject to all regular costing requirements (e.g., allocability, reasonableness, allowable by terms of the award, incurred within award period).

COMPUTING DEVICES (UNDER $5,000 UNIT COST)

Applicable UG Sections: 200.33 200.48

200.89 200.439 200.453C

COMPUTING DEVICES CAN BE INCLUDED ON COMPETITIVE AND NON-COMPETITIVE PROPOSAL BUDGETS.

Computing devices under $5,000/unit may be direct charged to the project or activity under the following

circumstances:

The machines are essential* and allocable to the project in that they are necessary to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting and receiving, or storing electronic information.

The project does not have reasonable access to other devices or equipment that can achieve

the same purpose; devices may not be purchased for reasons of convenience or preference.

Items costing more than $5,000 per unit are considered equipment and follow federal

equipment rules for when they can be direct charged. (SEE 200.33, 200.48, 200.89, 200.439)

* PIs are responsible for determining whether or not the device is “essential” and to what extent the cost of the device is allocable to the sponsored project. PIs and departments should maintain documentation that describes how the proposed computing device meets the above requirements and the allocation methodology used.

Uniform Guidance Quick Guide

PARTICIPANT SUPPORT

COSTS

Applicable UG Sections:

200.75 200.456

PARTICIPANT SUPPORT COSTS CAN BE INCLUDED FOR AGENCY APPROVAL ON COMPETITIVE AND

NON-COMPETITIVE PROPOSAL BUDGETS.

After UG implementation, participant support costs (see 200.75) are allowable with agency prior approval. This includes stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Participant support costs are not routinely allowed on research projects but can be charged if the project includes an education or outreach component and the agency approves such costs.

These costs should be explicitly listed in the proposal budget or approved by the funding agency after the

award has been made.

VISA COSTS

Applicable UG Section: 200.463D

SHORT-TERM, NON-IMMIGRATION VISA COSTS CAN BE INCLUDED ON COMPETITIVE AND NON-

COMPETITIVE PROPOSAL BUDGETS.

The UG allows short-term, non-immigration visa costs for a specific period and purpose as direct costs to federal awards. The person connected with these visa costs must be critical, necessary and clearly identified as directly connected to the work performed on the federal award. Because this is being classified as a recruiting cost, only the initial visa cost is allowable. J-1 and H-1B visas are for a specific period and purpose; therefore, these visa types are generally allowable if the specific conditions are met.

F&A ON SUBAWARDS

Applicable UG Section: 200.331

THE SUBRECIPIENTS’ NEGOTIATED F&A RATE OR AN ALTERNATIVE RATE AS DESCRIBED BELOW MUST

BE USED FOR ALL SUBAWARDS INCLUDED IN COMPETITIVE PROPOSALS.

If a federal program has a published statutory F&A cap, that rate must be used both by UC Davis and all of its subrecipients. For all other federal programs, if a subrecipient has a federally negotiated F&A rate, it must be used. If the entity does not have a negotiated F&A rate, a 10% de minimis F&A rate must be used instead. PIs may not negotiate or agree to lower rates with their subrecipients. There is no change to UC Davis recovery of its own F&A – this remains limited to receiving our F&A on the first $25K of each subaward.

FIXED PRICE/RATE

SUBAWARDS

Applicable UG Section:

200.332

AGENCY PRIOR APPROVAL IS REQUIRED TO ENTER INTO FIXED PRICE/RATE SUBAWARDS, WHICH MAY

NOT EXCEED $150K.

Agency prior approval is required to enter into a fixed price/rate subaward rather than a cost‐

reimbursement subaward, and the total value of each fixed price/rate subaward may not exceed $150K. Fixed price subawards are most commonly used for clinical trial site agreements, foreign subrecipients, and small businesses. To expedite agency approval, PIs/departments should add a new justification statement to proposals contemplating a fixed price/rate subaward. A statement is not needed for other subawards.

Uniform Guidance Quick Guide

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