Ohio Administrative Code › Title 3349 - Northeast Ohio Medical University › Chapter 3349-20 - Policy on Funds, Transfers, Unallowable Costs and Financial Conflict of Interest › Section 3349-20-15 - Direct charging sponsored projects and unallowable costs

Current through all regulations passed and filed through July 1, 2024
(A) Purpose
The university is required to ensure that any costs charged to
				federally sponsored programs follow costing requirements set forth in the
				office of management and budgets ("OMB") uniform guidance ( 2 C.F.R. 200 ).
				This rule also provides a foundation for direct charging costs to other,
				non-federally sponsored programs.
(B) Scope
This rule applies to all individuals involved in the decision
				making process for direct charging costs to sponsored programs.
(C) Definitions
Consult rule
				3349-7-01 of the
				Administrative Code.
(1) "Direct
			 Costs" refer to those costs that can be identified specifically with a
			 particular sponsored program. Direct costs must also be allocated to one or
			 more sponsored programs on a reasonable basis, where those direct costs benefit
			 multiple projects or activities. If a cost is already included in the indirect
			 cost rate (example, facilities and administrative costs rate), then it should
			 not be charged again as a direct cost.
(2) "Indirect Costs" or "Facilities and
			 Administrative Costs (F&A) " refers to those expenditures that have been
			 incurred for common or joint objectives and cannot be readily identified with a
			 particular sponsored program or activity. These costs consist of overall
			 support of sponsored research activities and are therefore recovered through
			 the university's "F&A" rate. Some examples include depreciation of
			 buildings and equipment, the costs of operating and maintaining facilities,
			 utility costs, library costs and general, department, and sponsored programs
			 administration.
(3) "Allowable
			 Costs" are those costs that are necessary and reasonable to perform the scope
			 of work of the sponsored program. Allowable costs must also conform to the
			 terms and conditions of the sponsor, of the award, and of the university's
			 policies and procedures, the award terms and conditions. Allowable cost should
			 be substantiated, by proper documentation or justification, to support its
			 allocation to the sponsored program(s) being charged.
(4) "Unallowable Costs" refers to costs that
			 are typically not permitted as direct or indirect "F&A" costs. Examples
			 include alcohol, entertainment, fundraising, development, and bad debts. There
			 may be sponsored programs that permit these types of costs in special
			 circumstances. Prior written approval is required from the sponsor before these
			 items can be purchased. Refer to the selected items of cost related to
			 sponsored programs document for additional items that may require sponsor
			 approval and are typically an unallowable cost.
(5) "Sponsored Program" refers to an award
			 funded via a grant, contract, cooperative agreement or subcontract from a
			 federal, state or local government entity, the private sector, or an
			 institution of higher education, whereby the university agrees to perform a
			 certain scope of work, in accordance with terms and conditions set by the
			 sponsor, for specific, budgeted monetary compensation.
(6) "Allocable Costs" refers to costs
			 incurred to benefit a sponsored program and charged based on the proportional
			 benefit of that cost to the sponsored program. If a cost benefits multiple
			 sponsored programs and/or other university activities, then the costs must be
			 allocated accordingly.
(a) If a cost benefits
			 two or more projects or activities, it must be charged in accordance with its
			 benefits to each project respectively. Charges split between more than one
			 grant must be split on the basis of proportional benefit or other reasonable
			 method. The division of the expenditure cannot be split based on available
			 funding or any other type of synonymous methodology. An expenditure that
			 benefited two or more projects cannot be charged solely to one project because
			 of funding constraints on another project.
(b) Any costs allocable to a particular
			 project may not be shifted to other sponsored programs in order to meet
			 deficiencies caused by overruns (deficits) or other fund considerations. Costs
			 cannot be shifted to avoid restrictions imposed by law, by terms of the
			 sponsored program, or for other reasons of convenience.
(7) "Consistent Treatment" means that each
			 item of cost incurred for the same purpose must be treated consistently in like
			 circumstances either as a direct or an indirect "F&A" cost in order to
			 avoid possible double-charging of federal awards.
(8) "Reasonable Costs" refers to costs
			 incurred that reflect the judgment a prudent person would have used under the
			 circumstances prevailing at the time of the decision. Costs must be reasonable
			 relative to the nature or type of cost incurred and the price paid for the
			 items in relation to the benefit received.