SECTION 16 - Grants and Research Contracts


SECTION 16.1.1 - Requirements of Cost Principles for Educational Institutions (OMB Circular A-21)
Urbana-Champaign Campus Supplement

Date: April 2002
Approved: Senior Associate Vice President for Business and Finance

Application of Policy Allowability Coding Unallowable Non-Personnel Expenditures
Coding Unallowable Personnel Expenditures Provisions for Selected Items of Costs

The federal government is the largest sponsor of research at the University of Illinois at Urbana-Champaign. It sets forth the principles for expenditure of federal funds in the United States Office of Management and Budget (OMB) Circular A-21 "Cost Principles for Educational Institutions." These cost principles are applied to federal funds, and to virtually all other units, whether or not they have sponsored projects, since a portion of their expenditures are used to develop the indirect cost rate.

OMB's Circular A-21 provides principles to be applied to selected items of cost to determine allowability as either a direct or indirect charge to federal projects. Many of these costs are allowable under University policy, but must be accounted for in a way that allows them to be identified and excluded from the indirect cost rate calculations.

APPLICATION OF POLICY

The policies for treatment of costs can vary by category of fund sources shown in the table below.

Category

Fund Source/Organizational Unit/Function

Ledger/Account Range

A

Academic units (colleges 15-79 and academic units located administratively in campus or university administration)

Ledger 1 – all
Ledger 2 – 10000 - 69999
Ledger 6 – 50000 - 51999

B

Academic units (colleges 15-79 and academic units located administratively in campus or university administration)

Ledger 2 – 70000 - 89999
Ledger 6 – 40000 - 49999

C

All units – federal sponsored projects (and federal pass-throughs in State Ledger 5 accounts)

Ledger 5 – 20020 - 34999
Ledger 5 – 40000 - 69999

D

Federal appropriations

Ledger 6 – 52100 - 85499

E

All units – non-federal sponsored projects (except federal pass-throughs in State Ledger 5 accounts)

Ledger 5 – 35000 - 39999
Ledger 5 – 80000 - 99999

F

Stores and services (except for CSO and AITS)

Ledger 3 – 10000 - 39999

G Campus and university administration units (College codes < 15 and NACUBO Function > 1200)

Ledger 1 – All
Ledger 2 – 10000 - 69999
Ledger 3 for CSO and AITS

H

Campus and university administration units (College codes < 15 and NACUBO Function > 1200)

Ledger 2 – 70000 - 89999

I

Library, Operation & Maintenance Division, Environmental Health and Safety

All ledgers


This section does not apply to the following sources of funds which are excluded from indirect cost rate calculations:

Account

Ledger

University Administration Gift accounts Ledgers 2, 6
Auxiliary accounts Ledger 3
Departmental activities Ledger 3
Auxiliary plant funds not charged back to units
or federally sponsored projects
Ledger 7
Agency Accounts Ledger 9

ALLOWABILITY

For a cost to be allowable as either a direct charge to a sponsored agreement or as part of an indirect cost pool it must be:

ALLOWABLE DIRECT CHARGES TO SPONSORED PROJECTS

Direct costs are those costs that can be identified specifically with a particular sponsored project or interrelated projects, or that can be directly assigned to such projects relatively easily with a high degree of accuracy. Direct charges cannot include the A-21 cost restrictions and A-21 unallowable costs described below.

A-21 RESTRICTED COSTS

A-21 restricts charging certain types of costs directly to federal sponsored projects, though in some instances they are permitted as direct charges if there is explicit justification for them. These costs are allowable charges to indirect cost pools. Examples include administrative salaries, memberships, postage, office supplies, and telephone monthly line charges. (See the table below for specific guidance.)

A-21 UNALLOWABLE COSTS

These are costs that are not allowable as either direct charges to federal sponsored agreements, indirect cost pools, or recharge centers. Examples include expenses associated with alumni relations, fund raising or development, community relations, investment management. There are also individual unallowable cost items, such as trustees' travel, fines and penalties, interest expense, etc. (See table below.)

Units may not charge A-21 unallowable costs directly to federal sponsored agreements (Ledger 5 federal accounts including State of Illinois projects using federal pass-through money and Ledger 6 federal) or to non-auxiliary Ledger 7 plant fund accounts. With appropriate accounting procedures described in this section, A-21 unallowable costs may be charged to Ledger 1, 2, or 3 (10000 - 39999) stores/service accounts.

Costs allowable under University policy but not under A-21 can be charged to service accounts when such costs are essential for the management of the activity. They must be recorded in XXX9 object codes which are reserved for recording A-21 unallowable costs. When such costs become material, they could be disallowed in a federal audit, in which case the activity or its home unit would be responsible for reimbursing the federal government for disallowed costs related to charges to federal projects.

CODING UNALLOWABLE NON-PERSONNEL EXPENDITURES

Non-personnel expenditures which are unallowable under A-21 cannot be charged directly to federal projects (unless specifically allowed in the terms of a sponsored agreement) and must be coded in UFAS when charged to institutional funds so that they can be eliminated from the indirect cost rate calculation. This coding can be accomplished in one of two ways:

CODING UNALLOWABLE PERSONNEL EXPENDITURES

Academic personnel – Expenditures are classified through the Activity Reporting System which identifies A-21 unallowable effort for public relations, organized fund raising, alumni relations, and other A-21 unallowable activities. This information is captured for all academic employees through the Activity Effort Plans submitted by campus units at the beginning of each academic year, and updated as significant changes occur. If the individual's duties formally include some percentage appointment for one or more A-21 unallowable activities, that effort should be reported in the "A-21 unallowable activity" category of the Activity Effort Plan. Note, however, that the time of unit heads, deans, and directors is not coded in the A-21 unallowable activity category unless fund raising is an individual's sole responsibility.

Staff personnel – Expenditures in support of A-21 unallowable activities must be handled as follows:

There are special provisions for charging administrative and clerical staff directly to federal sponsored projects. (See Section 16.1.3, Compensation for Personal Services Charged to Sponsored Projects for circumstances under which these costs may be charged directly to federal sponsored projects.)

In case of a discrepancy between the provisions of a specific federal sponsored agreement and the provisions below, the agreement should govern.

ADDITIONAL SPONSOR-SPECIFIC RESTRICTIONS

Sponsors may restrict allowability of costs in several ways:

Additional restrictions included in any of the above take precedence over this policy.

PROVISIONS FOR SELECTED ITEMS OF COSTS

The following table illustrates the principles to be applied in establishing the allowability of certain items of cost under A-21.

Cost

Treatment

Explanation

Administrative Salaries

C – Restricted

All other categories – Allowable

The salaries of staff employees in the groups listed [on the following page/below] are normally indirect costs and may not be charged as a direct cost to a federal Ledger 5 sponsored project except under the following conditions: 1) they are specifically budgeted and approved by the sponsor, or 2) they are secretarial salaries and are rebudgeted by the principal investigator in a manner consistent with the six criteria stated [on the following page/below], or 3) they are other-than-secretarial salaries and rebudgeted with the approval of the Grants and Contracts Office. This restriction applies equally to personnel appointed by a unit, charged through a GLDS account, appointed as extra help, or hired through an employment agency. They may be charged to ledger 5 non-federal funds. All other staff salaries may be charged as a direct cost.


Administrative Salaries
(continued)

Direct – Restricted

Indirect – Allowable

Employee Group Rank/EEO Code Class Code Object Code

ADMINISTRATIVE 1XXALL1310


ACCOUNTANTS/PROFESSIONALS

Accountants/Fin. Professionals 301ALL1340

Data Processing Sys. Analyst Prof. 304ALL1340

College Administration 308ALL1340

Other Professionals
   Excluding: Naturalists
   Horticulturists
310
310
310
ALL
2698
2128
1340
1340
1340


CLERICAL

Bookkeepers 401ALL1331

Office Machine Operators 403ALL1331

Storekeepers/Dispatchers
Excluding*: Storekeeper 1
    Storekeeper 2
    Storekeeper 3
    Store Supervisor
404
404
404
404
404
ALL
3317
3318
3319
3606
1331
1331
1331
1331
1331
  *Storekeepers are to be charged as a direct cost through Service Activities.

Other Clerical405ALL1331

Secretarial**402ALL1332

Secretarial** (GLDS)402ALL4227

Secretarial/Clerical** Temporary    1610

Secretarial/Clerical** Extra Help    1620

Secretarial/Clerical **Stenographic    531X

Secretarial/Clerical **Employment Agency    532X
  **Secretaries and similar administrative employees may be charged directly to non-federal sponsored projects, and to federal sponsored projects under circumstances enumerated by the Office of Management and Budget.

  1. Large, complex programs.
  2. Projects which involve extensive data accumulation.
  3. Projects that involve meeting arrangement for large number of participants.
  4. Projects whose principal focus is the preparation and production of publications.
  5. Projects that are geographically inaccessible.
  6. Individual projects requiring project-specific database management, individualized graphics or manuscript preparation, human or animal protocol, IRB preparations and/or other project-specific regulatory protocols, and multiple project-related investigator coordination and communication.

Advertising

C, D – Restricted

All other categories – Charge to object code 414X

Direct charges are restricted to recruiting personnel for sponsored agreements, procurement of goods and services for sponsored agreements, and disposition of surplus/scrap materials purchased with federal funds.

Advertising should be charged to object 414X. The Grants and Contracts Office will exclude these charges from indirect costs since it is difficult to determine allowability. Recruitment of students charged to function 14XX is an allowable student services activity cost.

Alcoholic beverages

B, H – Restricted

All other categories – Do not charge

Charge to Ledger 2 gift and Ledger 6 gift accounts and Ledger 3 departmental activity accounts established for conferences or similar events. Special campus approvals are required for purchasing and serving alcoholic beverages.

Alteration and renovation

C, D – Restricted

All others – Allowable

Alteration and renovation (work to change the interior arrangements or other physical characteristics of an existing facility) cannot be charged directly to a federal agreement unless it is included in the approved budget or specifically approved by the sponsor.

Alumni activity

C, D – Do not charge

A, B, E, F, G, I – Code as unallowable

H – Allowable without special coding

Unallowable under A-21 as a charge to federal funds, indirect cost pools, or stores and services recharge centers. For other fund sources, must be charged to accounts with NACUBO function XX99 or record in XXX9 object codes in all.

Animal Care

All categories – Allowable

Use 411X object code in recharge center charge backs and the appropriate object codes where animal care costs are not recharged.

Automobile Damage and Insurance

C, D and E – Do not charge

All other categories – optional

The damage insurance coverage offered by the UIUC carpool should be elected, because any damage incurred that would have been covered by the insurance cannot be charged to sponsored projects with the exception of the amount of the deductible. Any vehicle repair/replacement costs in excess of the deductible amount must be coded with XXX9 object code.

Automobile furnished by institution for personal use

C, D – Do not charge

All other categories – Code unallowable

The expense for cars used for the personal benefit of employees is unallowable under A-21, regardless of whether or not the cost is reported as taxable income to the employees and is treated in the same way as other goods and services for personal use. Charge to accounts with NACUBO function XX99 or record in XXX9 object codes.

Bad debts

C, D – Do not charge

All other funds – Use object code established for this purpose

Unallowable as a direct charge to a sponsored project for bad debts arising from uncollectible accounts, related collection costs, and related legal costs.

Bad debts charged to Ledger 1, 2 or 3 accounts are excluded from the indirect cost calculation by virtue of being charged to object codes 8610-19 "Bad Debt Expense."

Business meals and meeting costs

See Luncheons/Receptions in this table.

Commencement

C, D, E, F – Do not charge

A, B, G, H, I – Code as unallowable*

Unallowable as a direct charge to a sponsored project or service activity account. For other accounts, must be coded as unallowable, *except no coding is required for charges to student affairs accounts (NACUBO function 1400).

Communication Costs

See Telecommunication Services in this table.

Community relations

See Public/Community Relations in this table.

Compensation for personal services by Academics and Staff Exempt from the Fair Labor Standards Act

See Overtime for non-exempt employees

C, D – Special approvals required by University and sponsor

All other funds – Special approvals required by University

Charges for work performed on sponsored agreements during all or any portion of a project period are allowable at the base salary rate.

However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his regular departmental load, any charges for such work representing extra compensation above the base salary are allowable provided that such consulting arrangements are approved by the University, specifically provided for in the agreement, or approved in writing by the sponsoring agency or the sponsor has provided the University with greater authority to approve.

Computing services provided by CCSO or AITS

C, D, E – Do not charge*

All other funds – Allowable

The costs of these services area component of the f&a rate and therefore cannot be charged to federal sponsored projects *unless custom services are provided to meet a specific project objective.

Consultants

All funds – Governed by University policy

C, D – Additional restrictions by some agencies

University policy governs use of consultants in both sponsored projects and other University funds. Some agencies (NSF and NASA) limit consultant compensation to the GS-18 pay rate for federal employees.

Contingency reserves (not self insurance)

All funds – Unallowable

Unallowable, except for self-insurance reserves (see "Insurance Costs" in this table). These reserves are recorded in accounts monitored by the Office of Risk Management.

Contributions and donations to others

C, D – Do not charge

All other funds – Code as Unallowable

As a public institution, the University is rarely in a position to do this. Should there be any monetary contributions, they should be coded in the UFAS object code 4299 ("Miscellaneous Services").

Cost transfers

Cost transfers between or to sponsored agreements to eliminate overruns, to avoid restrictions imposed by law, or for other reasons of convenience are not permitted. (For additional information see Section 16.1.2, Cost Transfers.)

Defense and prosecution of criminal and civil proceedings

C, D – Do not charge

All other funds – Cost must be identified

Normally unallowable when the outcome is conviction or penalty. These costs are identified through a special study conducted by the Office of the University Counsel and excluded from the indirect cost pool.

Development

See Organized fund raising in this table.

Employee morale

C, D – Do not charge

All other funds – Allowable in accordance with University policy

Allowable on institutional accounts for awards, recognition dinners, and retirement and other such functions to the extent they are incurred in accordance with established University practice (see Section 8.13, Funding and Allowability of Certain Expenditures).

Employee training and development

All other funds – Allowable

To be allowable as a direct charge to a sponsored project, the project must benefit directly from the employee's training.

Entertainment

A, C, D, E, F, I – Do not charge

B, H – Allowable

Entertainment, defined as amusement, diversion, social activities and associated costs such as tickets to shows or sports events, meals, lodging, etc. is unallowable, and University policy prohibits such charges to institutional funds. (See Section 8.13, Allowability and Funding of Certain Expenditures). Entertainment costs may be charged only to Ledger 2 gift and Ledger 6 gift accounts or Ledger 3 departmental activity accounts established for conferences. No special object code is required, since these expenditures do not affect the University's indirect cost rate.

Luncheons and Receptions (business meals) are distinguished from entertainment by the fact that they take place in connection with University business.

Equipment

See Section 16.1.4, Equipment, Equipment Leases, and Expendable Supplies

Federal employees expenses while working in their official capacity

All funds– Do not charge

Unallowable under federal law.

Federal and state employees as paid consultants

All funds – Restricted

Federal or state employees may serve as paid consultants on projects only with prior approval from their agencies and when the services are performed outside their regular working hours or while they are on leave from official duties. Certain federal agencies impose additional restrictions which are embodied in their grant administration manuals.

Fines and penalties

C, D – Do not charge

All other funds – Code as unallowable

Unallowable if violations of federal, state, local, or foreign laws. Should any such payments be made, they should be recorded in object code 4299.

Foreign or commercial sponsored projects

C, D – Do not charge

E – Allowable

Cannot be subsidized by federal funds. See "Losses on sponsored projects" and "Cost transfers" in this table.

Fund raising

See Organized fund raising in this table.

General Labor Distribution System (GLDS) Costs – other than secretarial

All funds – Allowable

See Overtime in this table.

General Labor Distribution System (GLDS) Costs – secretarial

C, D – Restricted

All other funds – Allowable

See Overtime in this table.

Goods and services for personal use (of University employees)

C, D – Do not charge

H – Allowable

All other funds – Code as unallowable

Unallowable and must be recorded either in a gift account, in an account with NACUBO function XX99, or in XXX9 object codes. In the case where a particular good or service is for both business and personal use, the proportion of personal use is reported, and the imputed value of such use is reported as personal income to the individual.

Graduate assistant tuition remission

C, E – Allowable where not expressly prohibited by sponsor

All other funds – do not charge

A graduate assistant tuition remission rate is negotiated with the federal government and applied to the salaries of graduate assistants with waivers whose salaries are charged to sponsored projects. These salaries are recorded in UFAS object codes 1211, 1221, 1291, specifically established for this purpose.

Housing allowances and personal living expenses of University/ Campus Officers

C, D – Do not charge

H – Allowable

All other funds– Code as unallowable

Unallowable for current and past University campus officers. Treated the same way as other goods and services for personal use.

Human subject costs

All funds – Allowable

Human subject costs are treated as direct costs in the indirect cost study, and must be identified by use of the 412X object code for all sources of funds

Income and other applicable credits

All funds – Restricted to the source of funds that incurred the expenditure

Must be used to offset or reduce direct or indirect cost items (for example, purchase discounts, rebates, allowances, proceeds from sale of animals). Must be applied to the source of funds that incurred the expenditure.

Insurance costs

C, D – Restricted

All other funds – Restricted

To the extent shipping insurance is included in freight fees, this insurance cost could be charged directly to federal sponsored projects. Otherwise, direct charges to federal funds are restricted to insurance required or approved, and maintained pursuant to the sponsored agreement.

For indirect, code the following types of coverage as unallowable: Insurance on government-owned property unless specifically required and approved by the federal government, insurance against defects, and insurance on officers' and trustees' lives (in excess of the standard fringe benefits package). These costs should be recorded either in gift accounts, accounts with NACUBO function XX99, or in object code 4139 "A-21 unallowable insurance premiums."

Other insurance – including casualty, malpractice and liability insurance and self-insurance reserves is allowable on non-federal funds if the cost and extent of coverage is in accordance with sound institutional practice.

Interest

Both – Restricted and must be coded as explained

Interest is an allowable cost only when the following conditions are met: The acquisition or fabrication cost is $10,000 or more from any of the fund sources covered by this policy, and prior, written approval has been obtained from the federal government (see Section 16.1.4, Equipment, Equipment Leases, and Expendable Supplies). Federal approval is sought at the unit's request by the Grants and Contracts office.

Unallowable for borrowed capital or temporary use of endowment funds. Late payment penalties, though not specifically addressed under A-21, are treated as unallowable. All late payment penalties are charged to UFAS expense object code 8691 "late payment penalty" to ensure they are excluded from the indirect cost rate calculation. Other kinds of interest expense should be coded as 8629 "A-21 unallowable interest expense." In the case of a federal project, interest expense and late payment charges must be assessed against a campus unit account.

Investment management

All funds – Unallowable
Use accounts with NACUBO function XX99

Unallowable and the entire costs of the Office of Cash Management and Investments is excluded from the indirect cost study.

Lobbying costs

C, D – Do not charge

Indirect – Code as unallowable

The Office of Governmental Relations' expenditures are excluded from the indirect cost calculation. The office is responsible for determining whether other individuals who, in the course of their University duties, undertake lobbying contacts to the extent of being covered by the Lobbying Disclosure Act of 1995. Any such salaries and associated costs would be identified and excluded from the indirect cost study.

Activities such as testifying before Congress, providing technical and factual presentations, and analyzing the impact of proposed legislation, are allowable. Traditional interactions among investigators and federal agency program officials are allowable.

Losses on sponsored projects

C, D, E, F – Do not charge

All other funds – Allowable, but must be coded

Including cost sharing and under recovery of indirect costs, cannot be allocated to another sponsored agreement. (For additional information on coding final overdraft transfers see Section 16.1.2, Cost transfers.)

Luncheons/Receptions (formerly business meals and meeting costs)

C, D – Do not charge

A, B, E, F, G, I – Restricted

H – Allowable

Although not explicitly prohibited, business meals and meeting costs have been the subject of a great deal of scrutiny. In conformance with National Science Foundation and National Institutes for Health policies, the University does not permit them to be charged to a federal project, except for awards in support of symposia, conferences, or other meetings. However, in cases where a federal project has routine visits from individuals such as project advisory board members, the cost of meeting expenses is allowable if provided for in the approved budget.

Allowable charges to campus and university administrative unit gift funds.

Restricted to meals and/or receptions when charged to all other sources of funds in situations where "there is a substantial and bona fide business discussion during, directly preceding, or directly following the meal" (from IRS guidelines defining "business meal"). Such functions might be part of workshops or conferences, Board of Trustees meetings, committee meetings that are part of a sponsored agreement, advisory committee meetings, and employee recruiting and recognition

For charges to non-federal funds, the Grants and Contracts Office will calculate an adjustment for unallowable costs by testing a statistical sample of these costs since it is difficult to determine allowability by reviewing UFAS transactions

Use object code 425X "Luncheons/Receptions".

Membership costs in civic or community organizations, social, or dining clubs

C, D – Do not charge

All other funds – Code as unallowable

Unallowable for a civic or community organization, country club, or social or dining club/organization. They must be recorded in object code 4179 or in accounts with NACUBO function XX99.

Membership costs in professional organizations, subscriptions, and conference registrations

C, D – Do not charge*

All other funds – Allowable

Direct – Do not budget on (or charge to) federal projects, with the *exception of that portion of membership fees identified by the organization as a journal subscription (object code 415X) or meeting registration fee (object code 416X), which may be charged on the appropriate object code, assuming there is a direct benefit to the project. Documentation showing the breakout of these costs by the organization must accompany the voucher initiating such a charge to a federal project.

Indirect– Allowable under A-21 for memberships in professional, technical, and business organizations. Use object code 417X.

Moving Costs

See Relocation Costs in this table.

Office Supplies

Direct – Restricted

Indirect – Allowable

Direct costs are restricted to consumable supplies. Items used in the course of multiple activities of project personnel are "office supplies," while those used exclusively in support of the project are considered "consumable supplies." Charge directly only those items which: a) are consumed completely in the course of the project, b) can be demonstrated to be used only in the conduct of the project and are not used for other purposes.

Items such as lab notebooks, diskettes, transparencies, plotter pens, printer paper for research data and reports, pens, tablets, staples, file folders, binders, etc. that are used only for project purposes are justifiable. "Consumable supplies" also includes laboratory supplies and materials. Items that would likely be used for other purposes or not entirely consumed in the course of the project – wall clocks, calendars, waste cans, paper punches, University stationery, staplers, and the like – should not be charged directly to federal projects.

Operation and Maintenance costs incurred by departments for repairs, maintenance, utilities, equipment installation and remodeling

C, D – Restricted

Indirect – Allowable

Charges to federal projects are restricted to those that directly benefit sponsored project(s), that do not benefit other departmental activities, and that are necessitated by special requirements of the project.

The costs for installing utility services (electrical services, chilled water, gases, computer cabling, etc.) to laboratories or computer rooms where federal projects are conducted may be charged directly to federal projects, as can minor remodeling associated with equipment installation. The cost for extraordinary utility consumption may also be charged directly to sponsored projects, assuming adequate metering. Window air conditioners may be charged directly where they meet the criteria stated in the first paragraph above.

Purchase and maintenance of items for department-wide use, such as building deionized water systems, ice machines, glass washers, sterilizers, etc., cannot be charged directly to federal projects.

Organized fund raising

C, D, F – Do not charge

H – Allowable

All other funds – Code as unallowable

Organized fund raising includes financial campaigns, endowment drives, solicitations of gifts and bequests, and similar expenses incurred solely to raise capital or contributions. Expenses for established development offices, wherever located on campus, should be recorded in an account with an XX99 NACUBO function. If a unit without a formal development office has an individual whose duties formally include some percentage appointment for fund raising, that effort should be reported as fund raising in the Activity Effort Plan. The time of department/unit heads, deans, and directors are not charged to this account unless fund raising is an individual's sole responsibility.

Overtime costs

C, D – Restricted

All other funds – Allowable
consistent with University policy

Overtime for non-exempt employees, as a direct charge to a federal project, can be charged for activities such as experiments that are continuous in nature and cannot be reasonably interrupted or where such overtime results in lower overall costs to the sponsor. Overtime must be pro-rated to each account from which an employee is paid unless the overtime is clearly and demonstrably necessitated by demands placed on that employee on behalf of a specific project.

Patent costs incurred in preparing invention disclosures

All funds – Allowable

Costs associated with filing disclosures, reports, and other related documents to the extent that they are incurred outside the campus offices that deal with patent management, are allowable. See "Patent costs incurred by the Research Technology Management Office" in this table.

Patent costs incurred by the Research Technology Management Office

All funds – Unallowable

The costs of the campus offices are excluded from the indirect cost study.

Postage (including express mail) costs

C, D – Restricted

All other funds – Allowable

Postage may not generally be charged directly to federal projects. Where explicitly budgeted, postage costs directly related to the conduct of the project, including correspondence with the sponsor and project participants, surveys conducted by mail, and the like. Postage for continuation or renewal projects may be charged to a project only if a progress report is part of the proposal.

Pre-agreement costs

C, E – Restricted

D – Unallowable

Unallowable unless provided for in agency regulations or sponsored agreement terms and conditions. Federal agencies have generally authorized the University to incur pre-award costs up to 90 days before the official starting date of a research grant or cooperative agreement (see grant or cooperative agreement terms and conditions). Pre-award costs on contracts must be explicitly approved by the sponsor.

Profits and losses on dispositions of capital assets

Not considered in computing costs to sponsored projects.

Proposal costs

C, E – Restricted to continuations and renewals

D – n/a

All other funds – Allowable

Allowable as charges to institutional funds, but cannot be charged directly to federal sponsored projects except for continuation and renewal proposals that include a technical report from an on-going sponsored project which the proposal seeks to renew or continue.

Public/Community relations

C, D, F – Do not charge

All other funds – Restricted; coding required

Public relations are efforts dedicated to maintaining the image of the institution or maintaining or promoting understanding and favorable relations with the community or public at large.

Restricted to the costs of communicating accomplishments and results of sponsored activity, including the costs of conducting general liaison with news media.

Unallowable for expenses associated with such activities, which include convocations, open houses, and non-technical displays and exhibits. These costs should be coded as unallowable.

Recruiting costs

All funds – Allowable

Costs of "help wanted" advertising, travel costs of applicants for interviews for prospective employment, and relocation costs incurred incident to recruitment of new employees, are allowable to the extent that such costs are incurred pursuant to a well-managed recruitment program. Where the institution uses employment agencies, costs not in excess of standard commercial rates for such services are allowable.

Charges to federal projects are restricted to those associated with employees whose salaries are charged directly to sponsored project(s), and must be pro-rated if the full salary is not charged to a given project.

Relocation costs for employees who stay less than 12 months

All funds – Code as unallowable

Relocation costs for employees who stay less than 12 months are unallowable and must be charged to XXX9 object codes.

Sabbatical and other similar paid leave

C, D – Restricted

All other funds – Allowable to funds where salary when working is charged

A faculty member may combine sabbatical leave salary with salary supported by sponsored project funds administered by the University as long as the combined salary does not exceed the faculty member's 100% salary for the year in which sabbatical is taken and the contracting or granting agency approves such an arrangement. This means that an eligible faculty member may take sabbatical leave for one appointment year at one-half salary and the remaining half of the salary may be paid from a grant or contract administered by the University

Scholarships and student aid

C – Restricted

D, F – Unallowable

All other funds – allowable

Restricted to training grants and fellowship awards.

Selling and marketing costs of products sold by the University

C, D – Do not charge

All other funds – Code as unallowable

Unallowable for costs of any products sold by the University. Should any of these costs be incurred in institutional accounts (as contrasted to auxiliary accounts), they should be recorded in XXX9 object codes.

Service Activities (recharge centers)

See Section 13.6.2, Service Activities.

Severance pay in excess of regular University practices

C, D – Do not charge

All other funds – Code as unallowable in Effort Reporting System or with XXX9 object code

If excess severance pay is paid as salary, the effort associated with it should be coded as "A-21 Unallowable" in the Activity Effort Report. If excess severance pay is other than salary, the payment should be recorded in an XXX9 object code.

Student activity

C, D, E, F – Do not charge

All other funds* – Code as unallowable

Student activity costs such as intramural activities, student publications, student clubs, operation of the student union, must be recorded in XXX9 object codes or *accounts with 1400 (Student Services) NACUBO function.

Telecommunication services (monthly)

C, D – Restricted

All other funds – Allowable

Fixed, monthly costs of telecommunications services are allowable as a direct charge to a federal agreement only if the service is used exclusively for a sponsored project(s) and was justified in the approved budget or was explicitly approved by the sponsor.

The cost of telephone line charges for lines used only by sponsored project(s) personnel must be pro-rated based on the FTE's of project personnel or on some other defensible basis. If the cost is at all allocable to other activities it must be charged to institutional funds and not to sponsored projects.

The installation and monthly cost of ISDN lines, cellular phones, and other telecommunications services that go beyond basis telephone service can be charged to federal projects only with explicit sponsor approval.

Telephone toll charges

All funds – Allowable

Telegrams, telephone toll charges, etc. are allowable as a direct charge only when they can be specifically identified with a project or a set of interrelated projects.

Termination vacation and sick leave

C, E – Do not charge

All other funds – Handle in accordance with University policy and unit practice

Termination payouts are made to compensate employees for accrued but unused vacation and sick leave. They include both lump sum payments and appointments extended beyond the last date of service for the purpose of extending health insurance benefits. Such payments must be coded as termination vacation and charged accordingly.

Since these costs are recovered on sponsored agreements through assessment of the termination salary and sick leave fringe benefit rate, termination vacation and sick leave payments to terminating employees cannot be charged to sponsored agreements. The payments must be charged to institutional accounts or the Ledger 3 termination benefit accounts in selected colleges as appropriate.

Travel costs

Direct – Allowable in accordance with agreement and University policy

Indirect – Allowable in accordance with University policy

Unallowable for costs in excess of the University travel policy applied to state funds. Record in XXX9 object codes.

Travel for federal projects

For federally sponsored projects:

  • The air travel order (ATO) and travel voucher should indicate the purpose of the trip and the benefit to the project.
  • Each trip, including those made with personal car, must be authorized in advance by the head of the unit and by the college if required by college policy (see Section 15.1, Travel Regulations).
  • Domestic travel is defined as travel within the United States, its territories and possessions, and Canada.
  • Unless specified in the award document, foreign trips no longer require the specific approval of the sponsor except for foreign travel charged to the Department of Defense projects. If such approval is required, principal investigator must request written permission from the sponsor's contract and/or grants officer in advance of any foreign trip. To be assured of timely approval, the permission must be requested 60 days in advance.
  • The travel voucher should include specific documentation indicating how the travel directly benefited the project when:
  • The cost incurred is for personnel not paid from the Ledger 5 account
OR
  • The air travel order and travel voucher are charged to different Ledger 5 sponsored projects.
  • Business meals reimbursed to the employee through the travel voucher should be recorded with object code 425X (luncheons and receptions).
  • Air transportation to, from, between, or within a country other than the United States must be by a U.S. flag air carrier if such service is available. For travel purchased from a non-U.S. flag air carrier to be allowable (please refer to the sponsoring agency's grants administration manual or the individual agreement), the justification must be documented on the travel voucher or ATO.
  • Travel paid with federal funds cannot exceed the lowest available commercial coach fair, whether the actual mode of transportation is commercial airlines, University aircraft, personal automobile, train, etc.
  • The above two conditions must be met irrespective of cost, convenience, or personal travel preference.
  • A letter certifying that employees are traveling on a federal cost reimbursement contract (not a grant or cooperative agreement) is available from GCO. Such letter will provide the name, contract number, period, agency, etc. and may entitle the traveler to receive General Services Administration (GSA) discount rates from selected hotels/motels and air carriers.


Please send questions regarding this policy manual to OBFSPolicies@uillinois.edu.

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Last Updated: March 23, 2008