Federal regulations establish four cost principles for derterming costs applicable to awards. Seattle University applies these principles consitently across all sponsored projects.
All charges must be:
Costs expressly unallowable or mutually agreed to be unallowable shall be identified and excluded form any billing, claim, application, or proposal related to a sponsred projects. Sponsoring agenices use the term "allowable" to mean permitted as a cost within sponsor guidelines, the terms of a specific award, and/or the institution's policies.
A cost is allocable to a particular award if hte goods or services involved are able to be directly assigned to the award based on the benefit provided. To determine if an expenditure is allocable, ask yourslef the following quesitons:
If a cost is allocable to more than one award, please appropriately proportion costs by activity string within ProcureSU.
A cost may be considered reasonable if the nature of the goods or services, and the price paid for the goods or services, reflects the action that a prudent person would have taken given the prevailing circumstances at the time the decision to incur the cost was made.
To determine if an expenditure is reasonable, ask yourself the following questions:
All costs incurred for the same purpose, in like circumstances, must be treated uniformly either as direct costs or as indirect (F&A) costs. Since certain costs, such as salaries of administrative and clerical staff and office supplies are normally treated as F&A costs, these costs cannot be charged directly to federal Awards unless the circumstances related to a particular project are clearly different from the normal operations of the unit.
The PI/PD, with oversight by the Activity Manager, is responsible for spending the funds as proposed by the sponsor in adherence to the sponsor and university policies. All purchases within ProcureSU are also reviewed for allowability, allocability and reasonableness (as defined above) by the Grant Accountant prior to approval.
When the purpose of the purchase is not obvious, include a comment about how the purchase benefits the grant project. This will help expedite approvals for payment and help when documents are reviewed for audit.
Please review the Procurement Thresholds in the below section for further details.
To ensure that the university continues to obtain goods and services at the best value, the following methods of competitive bidding are required for all new contracts or non-contracted purchases. If assistance is needed, it is recommended to engage the Procurement Department early in the bidding process. Note: Sponsored Project procurement thresholds are different from general SU procurement thresholds.
|Dollar Amount||Bidding Requirements||Bidding Process|
|$0 - $3,000||verbal quote required||If pricing is considered reasonable, there is no requirement to solicit a competitive quote/proposal.|
|$3,001 - $50,000||2 written quotes required||Obtain a quote/proposal from at least 2 qualified sources for supplies or services. Include documentation from both sources with the requisition.|
|$50,001 - $150,000||3 written quotes required||Obtain a quote/proposal from at least 2 qualified sources for supplies or services. Include documentation from both sources with the requisition.|
|over $150,000||RFP/RFQ competitive proposals||The University will evaluate the proposals received and award the contract to the responsible firm whose proposal is most advantageous to the program, with service levels, price and other factors considered.|
|Sole Source||If only one source is qualified to provide the goods and services, it is an emergency purchase or required by a federal awarding agency, the purchase may be made without competition. The Sole Source Justification form must be completed.|
Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the sponsored award. Cost sharing, also known as “matching funds” or “in-kind support”, is funded by Seattle University or a third-party, which is generally a non-federal resource.
Cost-share requirements are determined in the proposal stage and if included in a proposal and subsequent award, cost-share will be held to the same standards as the sponsor funded award in regards to personnel, purchasing, prior approvals, tracking, reporting, and spending down. All committed cost sharing must be tracked and may require reporting.
Seattle University’s policy is to charge the federally negotiated indirect rate to all publicly-funded sponsored projects. Privately-funded grant indirect costs are charged at the accepted rate of the sponsor, as negotiated by the Director of the Office of Sponsored Projects at the time of the proposal submission.
Indirect costs include the facilities and administrative costs that are not easily assigned to specific projects such as physical building space, utilities, technological services, minor office supplies and printing, and administrative staff of the department and university, among other real costs. Please review the SU Indirect Policy for more information. When an indirect or administrative rate are charged to a grant, the items considered indirect costs cannot be directly charged to the award.
The Grant Accountant will charge indirects, based on your expenses, to your budget at the end of each month.
Purpose: to ensure your records match with the official institutional records. By tracking expenses and reconciling on a monthly basis, you can identify mistaken charges, anticipated charges that are missing from the university’s official record, or capture charges missed from your records.
Monthly: At the end of each month's financial close (approximately 2-3 weeks after the end of each month), the Controller's Office will send an email to all Activity Managers announcing the close of the month. At this time, the Activity Manager must reconcile their records with the controller's monthly financial report provided in InformSU.
Quarterly: After the end of each fiscal quarter while your sponsored project is active, the Grant Accountant will send a summary report of your financials comparing actuals to date with total budget, rate of spending, and project timeline complete (% of total award period already complete). This report must be signed by the sponsored project's PI/PD and budget manager certifying that the charges are correct.
If an error or unallowable cost has been discovered, the PI and Budget Manager must complete a standard Journal Entry form and an additional grant-specific Cost transfer justification formto remove the unallowable cost.
JEs should only be used to correct errors and not as a mechanism to regularly shift expenses from a different account on to a sponsored project account. This is a highly discouraged situation as it can raise red flags during an audit.
The PI, with support from their Activity Manager, is responsible for spending their sponsored project funds and associated cost share (if applicable) at the rate proposed in the project’s plan. Good communication and timely review of financial information by both the PI and Activity Manager will help avoid spending spikes, address potential audit questions, and facilitate close-out of the award.
Activity Managers should work with their PIs to develop a spending plan for a controlled spend of the award dollars to avoid a spike of spending toward the end of the award period due to inadequate financial planning. Spending spikes not only pose an audit risk, but often result in unallowable costs that require transfer off of the award.