Normandale Community College Policies and Procedures

9.9.1 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:

§200.403 Factors affecting allowability of costs.

§200.404 Reasonable costs.

§200.405 Allocable costs.

§200.31 Disallowed costs.

Purpose: To detail the process for ensuring that all expenditures on grant-funded projects meet federal requirements for allowability, reasonableness, and allocability.

Part 1:

  1. Upon receipt of an award, a project orientation meeting is held at which time the budget is reviewed on a line-by-line basis with the Principal Investigator/Project Director (PD), PD’s Supervisor, Grants Specialist, Grants Accountant and other key grant personnel.
  2. During the project orientation meeting, the Grants Specialist presents the Grants Management Handbook to the Project Director for review. The handbook:
  3. Presents allowable and allocable expense information, including a copy of Normandale Policy 9.9 and Procedure 9.9.1 Allowability of Costs Charged to Federally-Funded Awards
  4. Documents how personnel expenses are charged to the project, and
  5. Describes purchasing forms and policies.
  6. The Project Director and their Supervisor are given a list of costs that are not allowable under Federal awards.
  7. A unique cost center number and general ledger number are assigned to the grant award and used to segregate, by grant award, the budgeted and actual expenditures within Normandale’s financial records.
  8. Each year the grant budget is entered into Normandale’s accounting system under the assigned cost center number by the Grants Accountant.
  9. At any time, the Project Director can view budget and actual expenditure detail via Normandale’s online accounting system.
  10. On a monthly basis, the Grants Accountant sends a report to Project Directors, which compares budgeted and actual expenditures by budget line item.
  11. On a periodic basis, the Grants Accountant and the Grants Specialist meet with Project Directors to review the project budget and actual expenditures.
  12. Prior to approving expenditures to be charged to a Federal award, the Project Director confirms allowability of the expenditure using the training materials received.
  13. In accordance with Normandale’s procurement process, procurement documents are reviewed to determine if a) there is a budget for the specific expense type, b) there are budgeted funds available and c) the costs were incurred within the approved period of performance, and approved by the PD’s Supervisor. Any questions on budget availability or Federal cost allowability are directed either to the Project Director, the Grants Accountant or the Grants Specialist.
  14. The Grants Accountant and Grants Specialist review and respond to questions related to budget availability and allowability of Federal award expenditures.
  15. If a direct unallowable expenditure is identified, the expenditure is not charged to the award. The unallowable expenditure must be charged to an alternate college sponsored cost center or not incurred.
  16. The Grants Accountant and Project Director will confer prior to processing invoices from subrecipients to determine if a) there is a budget for the specific expense type; b) there are budgeted funds available; c) the costs were incurred within the approved period of performance and d) the type of expenditure is allowable under Federal award regulations. The Grants Accountant maintains a spreadsheet of invoice amounts by budgeted line item as a component of this review.

Procedure History:

Date of Adoption: 2020

Department Owner: Grants

Date and Subject of Revisions:

Next Review Date: 4/12/2023