This GIM is updated to conform to the Federal "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" (Uniform Guidance) effective December 26, 2014. This GIM applies to new awards and new funding for existing awards received on or after Dec 26, 2014.
For awards in existence prior to December 26, 2014 that have not received supplemental funding or are not otherwise subject to the Federal Uniform Guidance per sponsoring agency award terms and conditions, please refer to the Archived GIM 23.
Sponsored programs incur costs in support of the sponsored research, instruction or other sponsored activity that is carried out under the program. The University maintains this policy in order to ensure those costs are necessary, reasonable, and allocable to a particular sponsored program and administered consistently across all sponsored programs. The University maintains this policy, systems, internal controls and procedures that ensure that direct costs and associated indirect costs, consisting of and referred to as Facilities & Administrative (F&A) costs, are presented appropriately in proposal budgets and charged consistently to sponsored program accounts (budget numbers).
This policy applies to all funding accepted by the Office of Sponsored Programs (OSP) on behalf of the University of Washington.
Per Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Chapter I, Chapter II, Part 200, Uniform Guidance), federal cost principles must be applied uniformly to all federal awards and must be consistent with policies and procedures that apply to both federal awards and other activities of the university, including non-federally supported programs. Along with the general provisions of Uniform Guidance, these cost principles are also subject to agency- and announcement-specific restrictions as well as the terms and conditions of the federal award.
Cost principles are those factors that are used to assess allowability of costs. These principles state that costs must be necessary, reasonable and allocable, and conform to limitations set out by regulation and the award itself. Additionally, a cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost (F&A).
As §200.412 of the Uniform Guidance states, "There is no universal rule for classifying certain costs as either direct or indirect (F&A) under every accounting system. A cost may be direct with respect to some specific service or function, but indirect with respect to the federal award or other final cost objective. Therefore, it is essential that each item of cost incurred for the same purpose be treated consistently in like circumstances as a direct or indirect (F&A) cost in order to avoid double-charging of federal awards."
UW Principal Investigators and Departments, Divisions, Schools and Colleges, Grant & Contract Accounting (GCA), Management Accounting & Analysis (MAA), Office of Sponsored Programs (OSP).
All direct costs charged to a sponsored program must be necessary, reasonable, and allocable to the particular program and be incurred within the limitations set out by the sponsored award document and sponsor specific requirements, which may include seeking approval prior to charging certain costs to the award.
Any cost that is considered an F&A cost, such as administrative or clerical services, cannot be directly charged to a federally funded sponsored program unless certain conditions are met to justify the direct charging of the cost and prior sponsor approval is sought and obtained, consistent with the sponsor's definition of prior approval.
Costs that are normally recovered under F&A may be directly charged to non-federally sponsored programs if permitted by the sponsor's policies, award terms and conditions, or are otherwise approved by the sponsor.
Any costs that are proposed or incurred as cost-share in support of the sponsored program must also follow these cost principles (see GIM 21).
The programmatic lead of the sponsored program (Principal Investigator) shall put into place adequate internal controls to reasonably ensure that all expenditures associated with the sponsored program are consistent with this policy (see GIM 2). Costs determined to be unallowable, through the audit process, by the sponsor, by the pass-through entity, by Grant and Contract Accounting (GCA) post-award compliance monitoring, or other body with oversight regarding sponsored program expenditures, become the responsibility of the PI for payment from alternative sources.
This policy and associated procedures are consistent with the Cost Accounting Standards (CAS) as disclosed on the University's Disclosure Statement (DS-2), which describes the University's cost accounting practices.
Costs considered direct costs
Costs considered facilities & administrative (F&A) costs (indirect costs)
Costs requiring prior sponsor approval
Distribution of costs across two or more sponsored programs
|Federal Cost Principles||Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Chapter I, Chapter II, Part 200, Uniform Guidance|
|OSP Concurrence Letter (Prior Approval) information||OSP Manage Award webpage|
|Prior Approval Matrix for Certain Federal Agencies||Federal-Wide Research Terms and Conditions webpage (hosted by NSF)|
|F&A rate proposal information (direct versus indirect)||UW Management Accounting and Analysis F&A Rate and Proposal information|
Costing Policy, Proposal Budgets and Prior Approval Requirements: Office of Sponsored Programs, OSP website, firstname.lastname@example.org, (206) 543-4043
Costing Policy and Expenditures on Sponsored Program Budget Numbers, F&A Charges: Grant and Contract Accounting, email@example.com, (206) 616-9995
F&A Cost Calculation, Cost Accounting Standards: Management Accounting & Analysis, MAA
Office of Sponsored Programs
Grant and Contract Accounting
This policy is reviewed by the Office of Sponsored Programs as necessary to reflect changes in Federal regulation or University policies.