Normandale Community College Policies and Procedures

9.9 Allowability of Costs Charged to Federally-Funded Awards

Related Policy from the Code of Federal Relations – Title 2 Subtitle A Chapter II Part 200

UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (Uniform Guidance):

§200.403 Factors affecting allowability of costs.

§200.404 Reasonable costs.

§200.405 Allocable costs.

§200.31 Disallowed costs.

Purpose: To ensure that costs charged to each award are allowable, reasonable and allocable under 2 CFR Part 200, under additional cost principle(s) applicable to each specific grant, and under the terms and conditions of each applicable Federal award agreement. Normandale Community College is committed to stewardship of Federal grants in accordance with all rules and regulations.

Part 1: Definitions

  1. Allowable costs:
    • Are necessary and reasonable for the performance of the Federal award.
    • Conform to any limitations or exclusions set forth in the Uniform Guidance principles or in the Federal award as to types or amount of cost items.
    • Are consistent with policies and procedures that apply uniformly to both Federally-financed and other activities of the non-Federal entity.
    • Are accorded consistent treatment. (For example, 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.)
    • Are in accordance with Generally Accepted Accounting Principles (GAAP).
    • Are not included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period.
    • Are adequately documented.
  2. Reasonable costs: Costs that do not exceed an amount which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
  3. Allocable costs: Costs for goods or services involved which are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.
  4. Disallowed costs: Charges to a Federal award that the Federal awarding agency or pass-through entity determines to be unallowable, in accordance with the applicable Federal statutes, regulations, or the terms and conditions of the Federal award.

Part 2: Roles and Responsibilities

Principal Investigators/Project Directors: All Principal Investigators (PIs) and Project Directors (PDs) are responsible for ensuring that budgets and expenditures meet the requirements in this policy for allowability, reasonability, and allocability. They are responsible for monitoring budget to actual expenditures and for working with the Grants Specialist and Grants Accountant to address any expenditures that do not meet regulations and/or any budget overages in accordance with Procedure 9.9.1.

Grants Accountant/Fiscal Services: The Grants Accountant (and/or other designated individuals in the Fiscal Services department) acts as a resource to assist PIs/PDs and the grants specialist with any budget- or expenditure-related issues. The Grants Accountant assists with orientation/training of new PIs/PDs, provides regular financial reports to PIs/PDs, and reviews budgets and expenditures to ensure budget availability, Federal cost allowability and correct expense allocation.

Grants Specialist: The Grants Specialist provides technical assistance to PIs/PDs to ensure sound grant management and compliance with applicable regulations. The Grants Specialist is responsible for facilitating the orientation/training of new PIs/PDs and providing training on allowable costs, periodically meeting with PIs/PDs and the Grants Accountant to review budget and actual expenditures, and answering questions related to fund availability and allowability of expenditures.

Policy History:

Date of Adoption: 2020

Owner: Grants

Date and Subject of Revisions:

Next Review Date: 4/12/2023