Background

It is the policy of Davidson College to ensure that all costs proposed or incurred on a sponsored project comply with federal and state regulations and with the terms and conditions of the sponsoring agency in determining whether costs are allowable or unallowable.  At no time should unallowable costs be charged to a sponsored project. Proper accounting for unallowable costs is required to maintain the integrity of the College’s Facilities and Administrative (F&A) Cost Proposal and compliance with Federal regulations.

Uniform Guidance 2 CFR 200 establishes principles for determining costs applicable to grants, contracts and other agreements with Institutions of Higher Education (IHE). According to 2 CFR 200.403, costs must meet the following general criteria in order to be allowable under Federal awards:

  1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
  2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amounts of costs.
  3. Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
  4. Be accorded consistent treatment. 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.
  5. Be determined in accordance with generally accepted accounting principles (GAAP).
  6. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or prior period.
  7. Be adequately documented.

Purpose

The purpose of this policy is to establish guidelines for defining and identifying costs that are unallowable for reimbursement from the Federal government and other external sponsors as well as the proper accounting treatment for such costs.

Definitions

An “allowable cost” is an expense which can be charged against a sponsored project as well as placed in the indirect cost rate proposal based on the following factors. The cost is:

  • Reasonable – A prudent person would have purchased the item and paid that price.
  • Allocable – Expenses are at least partially applicable to a sponsored agreement.
  • Consistently Treated – Expenses for similar purposes must be treated the same way (throughout the college) under like circumstances.
  • Allowable – The expense must be allowable or not specifically excluded as specified by government regulations or by the contract/grant/cooperative agreement requirements.

 A “direct cost” is an expense that can be identified specifically with a particular project, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect (F&A) costs.

An “indirect (F&A) cost” is an expense that is incurred for common or joint purposes benefitting more than one cost objective, and not readily assignable to a specific project.

An “unallowable cost” is an expense that the federal government deems inappropriate and will not reimburse.  These categories are identified by the Office of Management and Budget in 2 CFR 200 (Uniform Guidance) and it is the college’s responsibility to maintain an accounting system that clearly identifies and segregates unallowable cost categories so that they will be excluded from the college’s proposals for cost reimbursement.

Please note that the term “unallowable” is defined by the federal government and is for the purpose of complying with federal costing regulations only. Certain types of expenditures, though not reimbursable by the federal government, are necessary for conducting college business and will continue to be reimbursed by Davidson College.

Policy

Unallowable costs cannot be charged (directly or indirectly) to federally-funded sponsored projects and must be excluded from the college’s indirect cost rate proposal calculation.  Listed below are unallowable costs that have been specifically identified in Uniform Guidance. However, this is not an exhaustive list and all expenses shall be subject to the same cost accounting principles governing cost allocability as allowable costs.

  1. Advertising and Public Relations - Some types of advertising, such as recruitment of research participants, may be allowable.
  2. Alcoholic Beverages
  3. Bad Debt
  4. Charitable Contributions
  5. Commencement and Convocation
  6. Contingency Provision
  7. Entertainment
  8. Fines and Penalties
  9. Fund Raising
  10. Goods or Services for Personal Use
  11. Housing and Personal Living Expenses for Institutional Officers
  12. Lobbying
  13. Membership in any civic or community organization, country club, social or dining club
  14. Selling and Marketing
  15. Student Activity Costs

Questions regarding the allowability and treatment of costs charged to sponsored projects should be directed to the Office of Grants and Contracts.

Responsibilities

It is the responsibility of each Principal Investigator (PI) to:

  1. Review sponsored research projects on a regular basis (e.g. monthly) to ensure that all expenditures charged are correct and appropriate.
  2. Identify and segregate unallowable costs when they are incurred and recorded.

It is the responsibility of the Grants Accountant to:

  1. Provide assistance in interpretation and implementation of this Policy.
  2. Provide training to PIs on this Policy.
  3. Periodically review ledgers to verify that charges are allowable and make necessary changes.

Unallowable cost items charged to sponsored funds that are subsequently identified during a review or audit of the project must be removed by the PI/department as soon as possible. The PI/department is responsible for absorbing these cost(s).

Administration of Policy

The Director of Grants and Contracts shall oversee this policy and review it at least once every two years.  Changes to this policy shall be made in accordance with the college’s Policy on Policies.

Adopted: 11/30/2015
Last Revised11/30/2015
Last Reviewed04/19/2021