Sharing Interpretations of Unique Allowable Cost Scenarios
There is so much knowledge in our SRAI community and frequently it can be challenging to disseminate that knowledge. In this article, Associate VP Jason Guilbeault will share a unique costing scenario that shows how Uniform Guidance regulations can be interpreted to discern which costs are allowable.
The Uniform Guidance (2 CFR 200) allows for the costs of publications – “Page charges for professional journal publications” - to be incurred on federal awards, even after the period of performance (i.e., start/end dates of an award), but before closeout when the final drawdown and submission of final Federal Financial Report (FFR) is completed. If we take a closer look at UG 200.461(b)(3), we’ll see that there is language that indicates that more than just publications are covered in terms of allowable expenses incurred after the period of performance.
- “The non-Federal entity may charge the Federal award during closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the Federal award.”
How can “or sharing of research results” be interpreted? In what ways do we share research results other than publications? Many of our researchers may travel to conferences to share their research results or disseminate information related to their award. Under this logic, you can draw the conclusion that travel for the purpose of sharing research results could be deemed an allowable cost, even if the travel occurs after the period of performance, but before submitting the final invoice/drawdown and completing the final FFR for the award.
Being a frequent reader of federal Office of Inspector General (OIG) audit reports, where other universities and research entities are audited by federal agencies, I’ve seen many audit findings where travel costs are deemed unallowable when it occurs after the period of performance of an award. In a grey area such as this, it is best to reach out to the federal sponsor to get their thoughts. I reached out to the National Institutes of Health’s Office of Policy for Extramural Research Administration to get their insights, as this was a hypothetical example and not one for which my university was actively seeking approval. The NIH’s take on this scenario was that this is an allowable expense:
- “…the federal cost principles would apply in this case. If the travel expense solely benefits the grant and is for the purpose of sharing research results, then it is an allowable cost in accordance with 2 CFR 200.461, which allows for costs outside the period of performance for these purposes. Given the gray area that you identified, to avoid auditor questions about allocability, reasonableness, and conformance, it may be appropriate to document the justification for incurring travel costs in closeout period specifically for purposes of sharing of research results.”
Despite this scenario being deemed allowable, there are some additional considerations and questions to ask when looking at these scenarios, such as: is the travel solely benefiting the award on which that the expense is being incurred? Careful consideration must be given to determine how much of any travel expense should be allocated to an award, as the trip may benefit multiple awards or even non-sponsored activity. If you were considering updating your policies to allow for travel expenses to be incurred as explained above, know that it can take additional time to monitor and implement additional controls to ensure compliance and obtain appropriate documentation to justify these scenarios, as NIH recommended above.
I believe we all have very interesting stories similar to the above. On behalf of SRAI, I hope you all consider submitting your own stories to the SRAI Catalyst and sharing your knowledge to help others who may have questions.
Authored by Jason Guilbeault, AVP of Sponsored Programs Administration, Executive Director of AU Research Institute
Augusta University
SRAI Distinguished Faculty
#Catalyst#february2024