Research & Cost Accounting

Administrative salaries funded by Rice University sponsored programs

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for direct charging of administrative and clerical salaries in like circumstances. The university is committed to ensuring that costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Rice University defines administrative staff as:

Staff are considered administrative or clerical, for purposes of sponsored programs, if their primary responsibilities include routine duties that are not in direct support of the sponsored program. Examples include, but are not limited to, general accounting tasks, filing, payroll processing, purchasing, or routine data entry.

Application

Federal awards

Under the guidelines imposed by the U.S. Office of Management and Budget’s Uniform Guidance 2 CFR §200.413(c), administrative and clerical salaries should normally be treated as Facilities & Administrative costs. Direct charging of these costs may be appropriate only if all four of the following conditions are met. If any one of these conditions is not met, the cost of the administrative or clerical salary will be borne by the department.

• Administrative or clerical services are integral to a program or activity.
• Individuals involved can be specifically identified with the program or activity.
• Such costs are explicitly included in the budget, or have the prior written approval of the Federal awarding agency when required.
• The costs are not also recovered as Facilities and Administrative costs.

If the four conditions above are met, the salary expense must be adequately documented, with a description of activities performed, in order to comply with 2 CFR §200.430. The documentation should be retained by the department.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-funded and other activities of the university. Therefore, Rice University Cost Principles Procedure, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for charging administrative or clerical salaries are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of administrative or clerical salaries should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

The administrative and clerical salaries cost should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

In the event that unbudgeted administrative or clerical personnel are required after an award is funded, the PI should work directly with SPARC to explain the benefit of this cost and determine if sponsor prior approval is required. The Office of Sponsored Projects and Research Compliance and  will review the justification to verify whether or not the costs meet the conditions of this procedure. In many cases, the terms and conditions of the award will require prior approval of the sponsor before implementing this change. In this event, SPARC will notify the investigator when sponsor approval has been given and the change may be implemented.

The written sponsor approval, as well as the justification explaining the purpose and benefit of the administrative or clerical salary to the specific program, will be retained by the department for future reference should the expenditure be questioned at a later date.

The Principal Investigator (PI) bears primary responsibility for management of the sponsored programs that are awarded to him/her. Management involves budgetary and cost compliance as well as technical compliance. This includes not only staying within the total program budget and time period, but also staying within specific budget. 

Computing devices funded by Rice University sponsored programs

Introduction

This document is intended to serve as formal guidance for Rice University regarding the purchase of computing devices with funds from sponsored programs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Computing devices are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR 200.20 and 2 CFR 200.94 as:

Computing devices means machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or "peripherals") for printing, transmitting and receiving, or storing electronic information.

Rice University considers computing devices to incorporate computers and electronic devices costing less than $5,000 per unit, including but not limited to: desktop computers and laptop computers, tablets, iPads, smart phones, e-readers, printers, and external hard drives. See the Procedural Statement for Equipment for computing devices costing more than $5,000 per unit. 

Due to the fact that these items are considered sensitive property by the U.S. General Services Administration 41 CFR 102-35.20, additional documentation is required to differentiate them from other general supplies.

Procedures

Federal awards

The Uniform Guidance states that computing devices are allowable as direct costs but do not need to be solely dedicated to a program, indicating that some non-program use is acceptable, although the predominant use of the computing device should be on the program. Costs of computing devices not related to the sponsored program must be allocated to an unrestricted source. 2 CFR 200.453(c) also states that “in the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal award”.

Principal Investigators shall explain how computing devices fit the criteria of being essential and allocable to the performance of their Federal award because of the following reasons:

• Computing devices have the capability for providing non-program benefit, and
• Computing devices are considered sensitive property by the U.S. General Services Administration and, as such, require special control and accountability.

It is important to review each award’s terms and conditions, as written sponsor guidelines may prohibit the purchase of computing devices on certain sponsored awards.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-funded and other activities of the university. Therefore, Rice University Cost Principles Procedure, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for purchasing computing devices are similar for non-Federal sponsored programs but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of computing devices should be provided in order to explain why these are essential to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

The computing device can be listed under supplies in the itemized proposal budget, but should also be identified separately in the proposal budget justification as to why it is essential and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the computing device. Written justification and approval are meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted computing device is required after an award is funded, the department can work directly with Research and Cost Accounting if questions arise about what is required to ensure that this purchase is properly documented. The purpose and benefit of the device to the specific program should be described in the justification and retained by the department for future reference should the expenditure be questioned at a later date. The justification may also be stored in an approved university procurement system with purchase documents.

If the documentation was not obtained at time of purchase, Research and Cost Accounting may ask for the documentation at closeout or during a periodic review of expenditures.

Conferences and Meetings

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for conference costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Conferences and conference costs are defined and described as allowable in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.432 as:

A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the non-Federal entity (Rice University) and is necessary and reasonable for successful performance under the Federal award.

Procedures

Federal awards

Allowable costs

When the non-Federal entity (Rice University) is a sponsor or host of a conference or meeting, the following items may be charged to the sponsored program as allowable costs: rental of facilities, speakers’ fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences, unless further restricted by the terms and conditions of the awarding sponsor. Some sponsors provide conference funding in the form of participant support. 2 CFR §200.432 allows for the awarding sponsor to authorize exceptions where appropriate for programs including Indian tribes, children, and the elderly.

The costs of all meals must be reasonable for the circumstances. Breakfast and lunch costs should not exceed $30 per person and dinner costs should not exceed $75 per person. These limits are established in the Travel, Business Meeting, and Entertainment Procedures of Rice University.

Appropriate documentation for allowable costs

In order to be compliant with the Uniform Guidance definition of a conference, documentation must be maintained by the department and should substantiate that the primary purpose was to disseminate technical information beyond Rice University.

Documentation should include, but is not limited to the following:

• A detailed explanation of the primary purpose of the conference, which must be the dissemination of technical information beyond the Rice University and must have a programmatic purpose that is necessary and reasonable to the successful performance of the award.
• A copy of the conference agenda to substantiate the primary purpose.
• A list of all registered attendees, both university and non-university.
• If the conference was a public event not requiring registration, proof of advertising beyond Rice University.
• Actual cost per meal for each guest.
• The Business Meals and Entertainment Expenses form should be used for documentation.

Unallowable costs

• Costs associated with intra-campus and interdepartmental meetings are unallowable as a conference cost.
• Uniform Guidance defines conferences as having a primary purpose of disseminating technical information beyond the non-federal entity (Rice University and the related program team, even if located at different institutions or campuses).
• Lunch meetings with collaborators and departmental retreats are unallowable as a conference cost, as they do not satisfy the definition of disseminating technical information beyond the Rice University and the related program team, even if located at different institutions.
• Alcohol costs are unallowable when paid for through sponsored program funding.
• Meal costs in excess of established meal allowances are unallowable.
• Locally available dependent-care resources for travel to conferences is allowed only if there is an institution-wide Procedure that these costs are allowed. The Rice University does not currently have a Procedure that provides this benefit to faculty and staff. Therefore, it is not allowable to charge dependent care costs to a sponsored program.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, the Rice University’ Cost Principles Procedure, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for charging conference costs are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of eachon-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of conference costs should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

At proposal

The conference cost should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

In the event that an unbudgeted conference cost is required after an award is funded, the Principle Investigator should review proposed conference costs for allowability and reasonableness and be able to explain the benefit of this cost. The Principle Investigator should then work with SPARC to obtain prior approval from the awarding sponsor. The written sponsor approval as well as the justification explaining the purpose and benefit of the conference to the specific program will be retained in the file for the award in Cayuse. Supporting documentation should include the items listed in the Allowable Costs section above and should be retained by the department for future reference should the expenditure be questioned at a later date.

If there are significant changes to the proposed conference between proposal and implementation, the costs may become unallowable, the conference costs will need to be re-reviewed by the Research Accountant, and additional justification will be required. Examples of what might constitute a significant change include changes to the purpose or scope of the conference, or a change to the composition or numbers in the attendee list.

Entertainment Costs

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for entertainment costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored program. Procedural statements support Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Entertainment costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR 200.438 as:

Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities).

Application

Federal awards

Under the guidelines imposed by the Uniform Guidance, entertainment costs are considered unallowable direct charges, except where specific costs that might otherwise be considered entertainment have a programmatic purpose and are authorized either in the approved budget for the Federal award or with prior written approval of the Federal awarding agency.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally funded and other activities of the university. Therefore, Rice University Cost Principles Procedure and related procedural statements are also applicable to non-Federal awards. The basic criteria for charging entertainment costs are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of entertainment costs should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

Entertainment costs that have a programmatic purpose for a specific program objective must be identified in the proposal budget justification and justified as to why they are necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost and is required by Federal agencies. For non-Federal sponsors, written justification and/or approval are meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

In the event unbudgeted entertainment costs are required after an award is funded, the PI must work directly with Sponsored Projects and Research Compliance (SPARC) to explain either their programmatic purpose for Federal awards, or the benefit of this cost for non-Federal awards. Based on sponsor prior approval requirements and the specific benefit, SPARC will contact the sponsor for allowability. The written sponsor approval, as well as the justification explaining the purpose and benefit of the entertainment cost to the specific program, will be retained in Cayuse for future reference should the expenditure be questioned at a later date.

Equipment

Introduction

This document is intended to serve as formal guidance for Rice University regarding the purchase, use and disposition of equipment costing $5,000 or more acquired with funds from sponsored programs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable and allocable to a particular sponsored award as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Equipment is defined in the U.S Office of Management and Budget’s Uniform Guidance, 2 CFR 200.33, as:

Tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds $5,000.
In Uniform Guidance, two main categories of equipment are classified as General Purpose Equipment and Special Purpose Equipment, which are defined below.

General Purpose Equipment is defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR 200.48, as:

Equipment which is not limited to research, medical, scientific, or other technical activities. Examples include office equipment and furnishings, modular offices, telephone networks, information technology equipment and systems, air conditioning equipment, reproduction and printing equipment, and motor vehicles.

Special Purpose Equipment is defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR 200.89, as:

Equipment which is used only for research, medical, scientific or other technical activities. Examples of special purpose equipment include microscopes, x-ray machines, surgical instruments and spectrometers.

The university also uses the following definitions:

Capital (Permanent) Equipment is defined as a tangible item that is durable, non-expendable, meets the university capitalization rules, and is by itself functionally complete for its intended purpose. Permanent equipment can include both Standalone Equipment and Fabrications that have been placed into service. Permanent equipment may also be referred to as either Capital Equipment or Fixed Assets.

A Fabrication is the transformation of materials, supplies and hardware into a one-of-a-kind piece of equipment or scientific instrument that meets a unique research need and that cannot be commercially obtained. Fabrications are expected to be operational, have a useful life greater than one year and have a total value of $5,000 or greater. A unique characteristic of a fabrication is that all the component parts are integral to the operation of the fabrication and removal of any of the components from the system diminishes its function and its ability to work as originally intended.

Capital Upgrades are improvements that add to the permanent value of equipment and must meet certain accounting standards in order to be capitalized. This means the total dollar value of the improvements are greater than $5,000 and they increase the useful life, productivity and/or efficiency of the equipment.

Application

Federal Awards

Section 2 CFR 200.439(1)(2) of the Uniform Guidance states that expenditures for general purpose equipment are unallowable as direct costs on Federal awards. However, expenditures for special purpose equipment are allowable, provided they have prior sponsor approval when required. Please note that while Federal regulations allow these expenditures, it is important to review each award’s terms and conditions, as specific written sponsor guidelines may be more restrictive.

Rice University considers the following criteria key elements in determining when special purpose equipment charges are allowable:

• The equipment is necessary to fulfill the objective of the program, or
• The program will be negatively impacted by not purchasing the equipment and
• The cost for the equipment is reasonable and represents prudent use of the sponsor’s funds.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-funded and other activities of the university. Therefore, Rice University’ Cost Principles Procedure and related procedural statements are also applicable to non-Federal awards. The basic criteria for purchasing equipment are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the purchase of equipment should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

Equipment should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the equipment purchases. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an Award is Funded, if sponsor prior approval is not required:

In the event that unbudgeted equipment is required after an award is funded, and sponsor prior approval is not required for either the purchase of unbudgeted equipment or the deviation from the proposed budget, the department should follow the campus guidance for documenting budget revisions. Substantiating documentation retained by the department should fully describe the purpose and benefit of the equipment to the specific program in the justification and include the criteria listed above to explain how this purchase is necessary and allocable to the program. The department is responsible for keeping and providing this documentation if it is not stored in Cayuse with other purchase documentation, in the event the costs are questioned in the future.

After an Award is Funded, if sponsor prior approval is required:

For Budgeted Items: On some awards, even equipment that has been listed in the budget must be approved specifically by the sponsor before it can be charged to the award. This is most often associated with contracts governed by FAR 52.245-1 but can also occur with specialized industry contracts. Prior to creating a requisition, the department should contact SPARC with information on the equipment that the department would like to purchase on the sponsored award. SPARC will contact the sponsor and request approval.

For Unbudgeted Items: In the event that unbudgeted equipment purchases require prior approval from the sponsor, the department will need to work with SPARC The purpose and benefit for the equipment, a justification for the deviation from the budget, and an explanation of the other budgeted costs that will be reduced in order to compensate for the unbudgeted equipment purchase should be provided to SPARC who will make a formal request for approval to the sponsor. If the sponsor approves of the unbudgeted equipment purchase, SPARC will notify the department, attach the approval to the requisition and upload the approval documentation into Cayuse. Research and Cost Accounting approval can be considerably delayed when the necessary sponsor prior approval has not been obtained, or if adequate supporting documentation has not been provided. Therefore, contact SPARC as soon as possible to avoid unnecessary delays.

Equipment purchased at the end of award

Equipment purchases charged directly to an award must be necessary for performance on the project; therefore, equipment purchases near the end (Less than 90 days from end) of an award period should and will have additional scrutiny and may be subject to project-specific justification and/or sponsor approval.

Special requirements for use, management, and disposal

2 CFR 200.313 of the Uniform Guidance provides requirements associated with using, managing, and disposing of equipment purchased with Federal funds. Rice University’s University Equipment policy outlines general procedures and standards by which our campus adheres to these Federal regulations. These standards apply to all equipment purchased with sponsored program funding, whether the funding is Federal or non-Federal. Therefore, please refer to this document for specific campus processes and procedures for the use, maintenance and disposal of all sponsored programs equipment.

Equipment acquired with federal funds must be used on the program for which it was acquired and be made available on other federally sponsored programs on a non-interference basis. In addition to helping maintain adequate records for the equipment, the department is also required to perform regular maintenance in order to keep the equipment in good working order. When the equipment is no longer needed for the program or for other federally funded programs, and there are no other existing obligations to the sponsor, the department can request to dispose of the equipment by following the campus procedures for surplus property disposal. However, Property Accounting must always screen disposal requests for equipment that was purchased with federal funds.

Direct / Indirect Costs

Introduction

This procedural statement governs the consistent treatment of the allocation of direct costs and indirect (F&A) costs charged to Federal and non-Federal grants, contracts, and other sponsored programs. The regulations for determining costs charged to federally sponsored programs at educational institutions are set forth in the U.S. Office of Management and Budget’s Uniform Guidance 2 CFR §200.400. This concept is reinforced and emphasized in the Cost Accounting Standards Board’s Cost Accounting Standards (CAS), particularly number 502.

Definitions

CAS 502 (48 CFR 9905.502-40) specifically says:

All costs incurred for the same purpose, in like circumstances, are either direct costs only or indirect costs only with respect to final cost objectives. No final cost objective shall have allocated to it as an indirect cost any cost, if other costs incurred for the same purpose, in like circumstances, have been included as a direct cost of that or any other final cost objective.

Direct Costs are defined by 2 CFR 200.413(a) as: 

Those costs that can be identified specifically with a particular final cost objective, 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.

Indirect (F&A) Costs are defined by 2 CFR 200.56 as:

Costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved.

In 2 CFR 200.414(a) “Facilities’’ is defined as depreciation on buildings, equipment and capital improvement, interest on debt associated with certain buildings, equipment and capital improvements, and operations and maintenance expenses.

‘‘Administration’’ is defined as general administration and general expenses such as the director’s office, accounting, personnel and all other types of expenditures not listed specifically under one of the subcategories of ‘‘Facilities’’.

Application

For any cost to be direct charged to a sponsored program, it must meet all the following criteria:

• Be allowable under university policy and procedures.
• Be associated with and directly benefit the objective of the program being charged.
• All costs must be proportionate to their level of use on that program.
• Such costs are explicitly included in the budget, or have the prior written approval of the Federal awarding agency when required.

This is true for both federally funded and non-Federal awards, and whether or not they are costs for situations that are considered to be either like or unlike circumstances.

The following costs are usually treated as F&A costs for sponsored projects. They may be treated as direct costs only under unlike circumstances.

• Salaries of administrative and clerical staff
• Office supplies: includes binders, folders, business cards, copy paper, envelopes, paperclips, pencils, pens, scissors, staplers, tape, message pads, etc.
• Postage, express delivery
• Toner cartridges and electronic storage media (diskettes, CD’s, etc.)
• Individual's subscriptions to business, professional, and technical periodicals
• Routine copying charges that cannot be identified with specific projects
• Basic local telephone services on campus – Basic services include phone installation, monthly line charges and ethernet charges
• Cellular phones, pagers and related service charges
• Local travel costs (meals, parking)
• Books for the library
• Proposal preparation (never a direct cost)

Like circumstances applicable to Federal awards

CAS 502 requires that costs charged to Federal awards need to follow a university’s normal treatment of such costs across all units of the university, considered like circumstances.

The following are examples of costs in like circumstances:

• Fringe benefit costs can be directly associated with payroll costs of all employees across the university and can therefore be tied to a particular cost objective with a high degree of accuracy. These are considered direct costs in like circumstances.
• General telephone and internet service is paid by the university for use across the campus. The cost of any general use of this service by a particular program or cost objective could not be easily calculated with great accuracy, therefore these are considered indirect (F&A) costs in like circumstances.
• University policy requires purchases of goods or services equal to or greater than $3,000 to include a purchase order, contract, or written agreement. Charges to Federal awards must also follow this treatment of costs.

Unlike circumstances applicable to Federal awards

In rare circumstances when certain criteria are met, CAS 502 contains an exception to the basic rules that allows for a cost that would normally be treated as an indirect cost to instead be direct charged to a federal award. An unlike circumstance may exist when an activity or the use of a cost item is substantively greater in amount or different in purpose than is typical.

The criteria needed to justify such exceptions include:

• The nature of the work, unique situation, or programmatic purpose creates an unlike circumstance
• The cost must be specifically associated with the sponsored program with a high degree of accuracy
• The cost must also meet all the general criteria for a cost to be direct charged to a sponsored program (allowable, reasonable, allocable and adequately documented)

On occasion, a Federal sponsor specifically requires a direct cost that would typically be considered an F&A cost. This would also be considered an unlike circumstance. In order to substantiate the exception, documentation must contain a description of the unique situation that creates the unlike circumstance.

For example: the program is supporting a 3-month field program located at a remote camp that is several hours from a population center by air. Certain office supplies normally considered to be indirect (F&A) costs must be purchased by the program for use at the base camp as they are otherwise unavailable. The cost will also need to be adequately documented at the time of purchase.

The following are examples to illustrate when a situation may or may not meet the criteria listed above.

1. A department has a system of tracking copy machine usage and can identify copies relating to a specific sponsored program. The copies made were for routine administration of the sponsored program, like copies of correspondence and progress reports. While this example does meet the criteria that the cost can be specifically associated with the sponsored program, with a high degree of accuracy, it does not meet the standard of an unlike circumstance. Rice University considers routine copies such as these to be an indirect cost and there is nothing unique about the situation to justify direct charging the copies to the sponsored program. However, if the sponsored program requires a large number of surveys in order to complete the scope of work, this does create an unlike circumstance. If the department used their tracking system mentioned above in this situation, the cost of the copies would meet the criteria in order to be direct charged.
2. If the department had a method to track actual postage used to mail the surveys, the postage cost could be direct charged because it meets the criteria of an unlike circumstance and is specifically associated with the sponsored program. However, if the postage was incurred for routine activities such as correspondence or progress reports, the postage cost would not meet the standard of an unlike circumstance and should not be direct charged.

Unlike circumstances applicable to non-Federal awards

Non-Federal programs at Rice University must follow the same policies and procedures Federal awards use for budgeting, justifying, expending, and documenting costs to their programs. 

Memberships, Subscriptions and Professional Activity Costs 

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for memberships, subscriptions, and professional activities in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Rice University defines memberships, subscriptions, and professional activities as:

• Memberships are fees or dues paid for an individual or an institution to join a technical, business, or professional organization for a specific length of time. Individual memberships are associated with, and provide benefits to, a single person only. Institutional memberships are associated with, and provide benefits to, an entire non-federal entity (Rice University).
• Subscriptions are payments in exchange for receiving technical, business, or professional periodicals or access to information (ex. inter-library searches or national DNA database).
• Professional activities are intended to enhance an individual’s professional development, including obtaining skills and qualifications in order to progress in his/her career.

Application

Federal awards

Institutional

Under the guidelines imposed by the U.S. Office of Management and Budget’s Uniform Guidance (2 CFR 200.454), costs for institutional memberships in business, technical, and professional organizations and institutional subscriptions to business, technical, and professional periodicals are allowable. The costs must be reasonable and allocable to the award. A brief justification for the costs must be documented with the expense. It is also Rice University’s position that sponsor approval is required prior to charging professional activity costs to a federal award.

Individual

Individual memberships are treated as indirect costs per 2 CFR 200 Appendix III.B.6.b.(2). The exception for individual memberships is when Rice University receives an award with an institutional allowance, and the Federal agency specifically allows direct charging of individual dues, or memberships, or subscriptions. In these cases, memberships, subscriptions, and professional activity costs may be charged directly to a sponsored program. Examples of these types of awards include NIH or NASA fellowships, training programs, or any other type of award with an institutional allowance. The membership, subscription, or professional activity cost should directly benefit the fellow or participant.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, Rice University’s Cost Principles Procedure and related procedural statements are also applicable to non-Federal awards. The basic criteria for membership, subscription, and professional activity costs are similar for non-Federal sponsored programs, but it is also important to be familiar with the requirements or restrictions of each non- Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of membership, subscription, and professional activity costs should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

Costs for dues, memberships, subscriptions, or professional activities may be included on a Federal proposal when the sponsor specifically allows these types of costs through an institutional allowance, or other identified support for career development. 

Some non-Federal sponsors may allow dues, membership, subscriptions, and professional activity costs to be direct charged. Review of the requirements and restrictions of the non-Federal sponsor is required to ensure allowability. If allowable, these costs should be identified in the proposal budget justification as to why they are necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the costs. Written justification and approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

Typically, when Rice University receives an institutional allowance, it is coded in the finance system. Review of the award document may be necessary to confirm that an institutional allowance was received. In addition, sponsor requirements and restrictions related to institutional allowances should be reviewed to ensure the institutional allowance may be used for these types of costs.

Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted (not specifically identified in the budget justification submitted with the proposal) membership, subscription, or professional activity cost is required after an  award is funded, the PI or department administrator should work directly with SPARC to document the necessity and benefit of the cost. If sponsor approval is required, the SPARC will contact the sponsor for approval. The sponsor approval (if required), as well as the written justification explaining the need and benefit of the cost to the specific program, will be retained by the department and in Cayuse for future reference should the expenditure be questioned at a later date.

Personnel recruitment costs

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for recruiting costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored research. Procedural statements support the Rice University Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Recruitment costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.463 as: 

Costs of “help wanted” advertising, operating costs of an employment office necessary to secure and maintain adequate staff, costs of operating an aptitude and educational testing program, travel costs of employees while engaged in recruiting personnel, travel costs of applicants for interviews for prospective employment, and relocation costs incurred incident to the recruitment of new employees.

Application

Federal awards

Under the guidelines imposed by the Uniform Guidance, recruiting costs may be considered allowable direct charges, provided that the size of the staff recruited and maintained is in keeping with workload requirements. Rice University considers recruitment costs to be allowable on sponsored programs if the position they are recruiting for is essential and allocable to the performance of the award. 

Recruiting is considered necessary when there is a need for a specialized individual with unique skills and expertise in order to complete the scope of work of the programs, and there are no available faculty or staff currently employed within the unit who could perform the same tasks. Eligibility is limited to faculty, associates, and post docs. Graduate Assistants are generally not considered essential personnel, so direct charging of recruiting costs to a sponsored programs for a Graduate Assistants is allowable only in exceptional cases.

Recruiting costs are considered allocable when incurred solely to advance the objective of the award. If the personnel being recruited will not be working on the sponsored programs full time, only the proportionate amount of the recruiting costs should be allocated to the sponsored programs.

Special salary payments, fringe benefits, and salary allowances incurred to attract professional personnel that do not meet the test of reasonableness, or do not conform to Rice University recruiting practices, are unallowable. Relocation costs (2 CFR §200.464) are allowable when incurred incident to recruitment of a new employee under certain circumstances. Please refer to the Procedural Statement for Relocation Costs for further guidance on relocation costs.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, Rice University Cost Principles Procedure and related procedural statements are also applicable to non-Federal awards. The basic criteria for charging personnel recruitment costs are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of personnel recruitment costs should be provided in order to explain why these are necessary to fulfill the objective of the programs, and to ensure that the cost directly benefits the programs being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

Recruiting costs should be identified in the proposal budget justification and justified as to how they are necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the recruiting costs. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

In the case of international recruitment:

• It must be specifically documented why this is necessary for the programs.
• International airfare related to recruitment on federally funded programs must adhere to the Fly America Act.
• Departments shall use the guidance provided by the Office of Research Compliance for determination of export control implications. 
• The department is responsible for notifying Human Resources of any potential export control implications related to the recruitment.

After an award is funded

Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted recruiting cost is required after an award is funded, the department should work directly with the assigned Research Accountant to ensure this cost is properly documented prior to the costs being incurred. The need for recruiting for a specific programs, and how it is necessary and allocable, should be fully described in the justification and retained by the department for future reference should the expenditure be questioned at a later date.

Research-related relocation costs

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for relocation costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Policy by providing definitions and processes for meeting those standards.

Definitions

Relocation costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.464 as:

Relocation costs are costs incident to the permanent change of duty assignment (for an indefinite period or for a stated period of not less than 12 months) of an existing employee, or upon recruitment of a new employee. Eligible employees are current employees with a 100% full-time equivalent appointment or new hires who will be in a 100% full-time equivalent appointment.

Application

Federal awards

Under the guidelines imposed by the Uniform Guidance, relocation expenses may be considered allowable direct charges under certain circumstances, subject to limitations. Rice University considers relocation costs for new hires or existing employees to be allowable on sponsored programs if the position is essential and allocable to the performance of the award. Eligibility is limited to faculty, associates, and post docs.

A position is considered essential under the following conditions:

• When there are no available faculty or staff currently employed by the Rice University unit who could perform the same tasks.
• When there is a need for a specialized individual with unique skills and expertise in order to complete the scope of work of the program.
• Graduate Assistants (GAs) are generally not considered essential personnel, so direct charging of relocation costs to a sponsored program for a GA is allowable only in exceptional cases.

Relocation costs are allowable on sponsored programs, provided that all the following conditions apply, and are subject to limitations outlined below:

• The move is for the benefit of the Rice University.
• Reimbursement to the employee is in accordance with an established written procedural statement consistently followed by the employer. (See Rice University Moving Expense Policy).
• The reimbursement does not exceed the employee's actual expenses. 
• International travel related to relocation on federally funded programs must adhere to the Fly America Act (see the Travel Procedure for more information).

Limitations on allowability

1.  For new hires, the relocation costs to be covered should be listed in the offer letter. Allowable relocation costs for current employees or new hires are limited to the items listed below:
   1. Moving the employee’s household goods and personal effects, including in-transit or foreign-move storage expenses
   2. Travel, including lodging but not meals, from the former residence to the new residence. This includes one night of lodging upon arrival at the new home destination. Subsequent nights of lodging are the responsibility of the employee.
2. If the newly hired employee resigns within 12 months after hire for reasons within his or her control, all associated relocation costs must be removed from the Federal award and charged to a departmental account. If the employee is terminated by the unit within 12 months, relocation costs can still be charged to the sponsored program. 
3. If an existing employee, or a new hire, is being moved to an overseas location, and both of the following conditions apply, the cost will be considered a travel cost in accordance with §200.474 Travel costs, and departments should follow the university's travel policy.

Unallowable costs

• Fees and other costs associated with acquiring a new home.
• A loss on the sale of a former home.
• Continuing mortgage principal and interest payments on a home being sold.
• Income taxes paid by an employee related to reimbursed relocation costs.
• Vehicle tags and driver’s license fees
• Security deposits and utility hookup fees

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, Rice University’s Cost Principles Policy, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for relocation costs are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of relocation costs should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

The relocation cost should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted relocation cost is required after an award is funded, the department can work directly with SPARC to ensure that this cost is properly documented (including any eligible charges paid by a new employee that would be reimbursed by Rice University with sponsored program funds). The documentation must be retained by the department and available upon request. The purpose and benefit of charging the relocation costs to the specific program should be fully described in the justification, and retained for future reference, should the expenditure be questioned at a later date.

Research-related visa costs

Introduction

This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for visa costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Visa costs are defined and described as allowable in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.463(d) as:

Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a Federal award.

Visa costs discussed in this procedure are specifically associated with sponsored program related visas. See International Students and Scholars for additional information on other visas. 

Application

Federal awards

Under the guidelines imposed by the Uniform Guidance, visa costs may be considered allowable direct charges under certain circumstances, and Principal Investigators (PIs) need to demonstrate that such costs fit the criteria provided in the Uniform Guidance.

Visa costs are allowable, provided that they meet all four of the following conditions:

• Be critical and necessary for the conduct of the program, and
• Be allowable under the applicable cost principles, and
• Be consistent with the university's cost accounting practices and procedural statement regarding sensitive expenses, and
• Meet the definition of “direct cost” as described in the applicable cost principles (2 CFR 200.413(a) and (b)).

The Uniform Guidance categorizes visa costs as a recruitment cost (2 CFR 200.463). Therefore, in like circumstances, visa costs are limited to initial costs only.

Allowable visa types:

• H-1B petition expenses: an H-1B visa is a non-immigrant visa that allows US companies to employ foreign workers in specialty occupations that require theoretical or technical expertise in specialized areas. If the individual is being recruited to work on the sponsored program, H-1B visa fees are chargeable to that sponsored program because that program will receive a direct benefit from the university’s appointment.
• O-1 Visas: an O-1 visa is a non-immigrant visa for an individual who possesses extraordinary ability in the sciences, arts, and education. O-1 Visas may be charged to sponsored programs if there is a clear and direct benefit derived by the sponsored program to justify charging the expenses.
• J-1 Visas: a J-1 visa is a non-immigrant visa issued to research scholars, professors, and exchange visitors participating in programs that promote cultural exchange. J-1 Visas are allowable when the purpose of the visiting scholar or faculty exchange is to work on one or more sponsored programs.

Unallowable visa types:

• All student (F-1) visas: the primary purpose of an F-1 visa holder is to join the university community as a student, and participation on sponsored programs is incidental to their roles as students.
• J-1 visas: the procedure generally excludes exchange visas for visiting scholars or professors to come to the US to participate in teaching, scholarship, or research, unless the purpose is specifically to participate in a sponsored program. (See J-1 Visas above)
• All permanent residency requests: the primary beneficiary for a Permanent Residency request is the individual, and direct benefits to individual sponsored programs cannot readily be shown.
• If the newly hired employee resigns within 12 months after hire for reasons within his or her control, all associated relocation costs, including any visa costs, must be removed from the Federal award and charged to a departmental account. If the unit terminates the employee, the costs are still allowable.
• Internal Rice University processing fees, and fees for expedited processing, cannot be direct charged to a sponsored program.
• Renewal fees for visas cannot be direct charged to a sponsored program as they are not part of the initial recruitment cost.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, Rice University’s Cost Principles Policy and related procedural statements are also applicable to non-Federal awards. The basic criteria for including visa costs are similar for non-Federal sponsored programs, but it is important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the sponsor, a justification for the inclusion of visa costs should be provided in order to explain why they are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program.

Process

At proposal

The visa cost should be identified in the proposal budget justification if possible, and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted visa cost is required after an award is funded, the department should work directly with their Research Accountant to ensure that this cost is properly documented prior to when the expense is incurred. The purpose and benefit of the visa costs to the specific program should be fully described in the justification and will be retained in Cayuse.

Travel

Introduction

This document is intended to serve as formal guidance for Rice University for charging travel-related expenditures to funds received from sponsored programs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.

Definitions

Travel Costs are defined in the U.S Office of Management and Budget’s Uniform Guidance, 2 CFR 200.474(a), as:

Expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-Federal entity.

Application

Federal awards

Section 2 CFR 200.474 of the Uniform Guidance states that expenditures for travel related expenses are allowable when in travel status on official business of the university. Please note that while Federal regulations allow these expenditures, it is important to review each award’s terms and conditions as sponsor guidelines may be more restrictive and may require specific sponsor prior approval, even when included in the proposed budget. When allowed by the federal sponsor, travel must be pre-approved on campus as prescribed by Rice University Travel Policy and determined by department, center, or institute policy.

Rice University considers the following criteria key elements in determining whether or not and travel charges are allowable:

• The travel is necessary to fulfill the objective of the program and it directly benefits the program being charged, and
• The cost for travel is reasonable and represents prudent use of the sponsor’s funds, and
• There is a clearly defined relationship between the traveler and how he/she supports the work of the program that is provided in the travel documentation. If the traveler receives salary from the program, that provides sufficient documentation of the relationship.

Allowable travel-related expenses

The Uniform Guidance specifically allows expenses for lodging, subsistence, and related expenses as long as they follow university policy and procedures. Therefore, travel expenses for these categories need to adhere to Rice University Travel Policy. Rice University provides additional requirements for sponsored program travel in this procedural statement. Transportation expenses are allowable but have additional Federal requirements that restrict the acceptable dollar amount that can be charged for these categories.

• Airfare: Costs must represent the basic least expensive available unrestricted accommodations class unless those would unduly prolong the trip, require travel at unreasonable hours, increase the routing, or add costs that offset the airfare savings. For Federal awards or when the sponsor requires it, ensure the carrier being used for foreign travel is in accordance with the Fly America Act 
• Car Rental: General Services Administration (GSA) Federal Travel Regulation (FTR) 301-10.450(c) stipulates that the least expensive compact car available must be used, unless an exception for another class of vehicle has been justified. Explanation for the exception can be provided in the proposal budget justification or, if needed after the award is funded, provided with the travel expense reconciliation and stored in Concur. Exceptions include, but are not limited to, when there are multiple travelers in the same vehicle, to accommodate a medical disability, the amount of equipment and/or materials to be carried will not fit into a smaller vehicle, etc. Refer to FTR 301-10.450(c)(1-6) for a full listing of allowable exceptions.
• International Travel: Travel internationally must abide by the Fly America Act and Open Skies Agreements. Please refer to the Cost Principles regarding international travel for more information.

Other allowable expenses

• Lodging: Lodging can be charged to a program if an overnight stay is necessary to complete the purpose of the trip and it directly supports the program being charged; Rice University considers the traveler to be in travel status when both of these conditions are met. The University will reimburse for a reasonable single occupancy, standard business room rate.
• Meals: Meals for the traveler can be charged to a program only while in travel status or for a day trip lasting longer than twelve hours, and must follow the per diem standards outlined in the Rice University Travel Policy.
• Travel Visas: If the destination country for the travel requires a visa to enter the country and the travel is required to fulfill program objectives, the cost of that visa is allowable for essential program personnel and should be included in the proposed budget. See Visa Policy.

Unallowable travel-related expenses

The Uniform Guidance identifies specific instances when travel expenses are unallowable.

• Business-Class or First-Class Airfare: This is unallowable except for travelers whose medical needs require these accommodations. These situations are analyzed by the university on a case-by-case basis and the traveler must provide a doctor’s statement explaining the medical need for this exception. In certain cases, sponsor pre-approval may be required.
• Travel Costs for Dependents: These are unallowable unless the travel is for six months or more and has sponsor prior approval.
• Temporary Dependent Care: Federal standards allow these costs only when provided for all qualified employees of the university. These costs are allowable if the costs are a direct result of travel under a sponsored award. Sponsor pre-approval is required.

Additionally, Rice University also disallows the following charges to sponsored programs in like circumstances:

• Passport Fees: Passports are active for 10 years and their use benefits multiple activities, including business and personal, as well as unknown future activities. Therefore, it would be problematic justifying this expense or allocating it with a high degree of reliability.
• Fees to Expedite Visa Processing: Fees to fast-track visa processing are not allowed.

Non-Federal awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, Rice University’s Cost Principles Policy and related procedural statements are also applicable to non-Federal awards. The basic criteria for charging travel expenses are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor.

When allowed by the non-Federal sponsor, travel must be pre-approved as prescribed by travel authorization which typically includes a written justification for travel in order to explain why this is necessary to fulfill the  objective of the program and to ensure the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.

Process

At proposal

Travel should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Whenever possible, international travel costs should be identified separately from domestic trips. Justification should clearly state the business purpose, the travelers intended for those trips, and how these trips directly benefit the program’s purposes. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the travel. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.

After an award is funded

In the event that unbudgeted travel is required after an award is funded and sponsor prior approval is needed, communicate with SPARC to contact the sponsor. If it is not required for either the specific trip or for the deviation from the proposed budget, the department should follow the campus guidance for documenting budget deviations (procedural statement coming soon). Substantiating documentation retained by the department should fully describe the purpose and benefit of the travel to the specific program in the justification, and include the criteria listed above to explain how travel is necessary and allocable to the program. The department is responsible for keeping this documentation and providing it if the costs are questioned in the future. When required, written sponsor prior approval will be retained in Cayuse.

When booking a trip

IRS rules (http://www.irs.gov/publications/p463/ch06.html) require business expenses to be documented in a timely manner. Undocumented, improperly documented or untimely submission of business expenses will require Rice to report these expenses as taxable income to the individual. Thus, travel, business meeting and entertainment expenses should be submitted and approved no later than thirty (30) calendar days after the return from a business trip or end of the meeting or event. 

Departments should have procedures in place to ensure appropriate prior approval is provided for all trips charged to sponsored programs, even if the trip was properly budgeted and/or the sponsor has provided specific prior approval. The Concur Travel system requires all international travel be approved by the department and by a University Officer before the university’s travel agency can book a ticket. Please ensure sufficient time is provided when planning international trips in order to accommodate the additional time needed to complete this system requirement.