How do I ensure that my lab uses supplies appropriately to comply with federal guidelines?
As long your overall budget allocation of supplies represents the overall usage of the eligible hESC lines ersus ineligible hESC lines, then it will be in compliance. Below are specific considerations to take into account when tracking supplies:
• Supplies originally purchased with non-federal sources should be allocated to research on eligible and ineligible lines in accordance with how they are consumed. For example, a lab purchases 100 boxes of pipette tips and charges the costs to a discretionary budget. 40% of the tips are ultimately used for ineligible lines and 60% for eligible lines. The charge to the discretionary budget may be adjusted by transferring 60% of the cost to federal dollars.
• A lab may use a single-purchase mechanism (e.g., a purchase order) to obtain supplies used for both eligible and ineligible lines by splitting the cost of the purchase onto separate budgets at the time of purchase. The percentage of costs charged to each budget on the purchase order must reflect the actual usage of supplies for eligible vs. ineligible lines.
• Supplies purchased with federal funds may not be used for ineligible lines.