The University of Kansas Center for Research, Inc. (KUCR) has compiled the following policy and procedures related to expenditure monitoring in accordance with the 2 CFR 200 Uniform Guidance (OMB Circular A-21, Cost Principles for Educational Institutions for federal awards issued prior to December 26, 2014).
All expenditures charged to externally-sponsored projects must meet the following criteria:
Costs must be reasonable. Both the nature and amount of a cost must reflect prudent action at the time the decision was made to incur the cost;
Costs must be allocable: A cost must be incurred solely to advance the work under the sponsored agreement. It must reasonably benefit the sponsored agreement. It must be necessary to the overall operation of the institution and can be assignable to a specific sponsored project;
Each cost must be given consistent treatment according to generally accepted accounting principles appropriate to the project; and
Each cost must conform to principles outlined in OMB circulars or specific agency guidelines.
Unallowable costs, which are not eligible for reimbursement on sponsored projects, include, but are not limited to:
- Administrative expenses, i.e., office support, chairs, furniture, and computers
- Commencement and convocation costs
- Contengency provisions
- Gifts, including flowers
- Alumni activities
- Bad debts/uncollectible accounts
- Donations and contributions
- Entertainment costs
- Fines and penalties
- Goods or services for personal use
- Memberships in civic, community, social, or proffesional organizations
In addition to Circular A-21, the University of Kansas Center for Research is required to comply with the following cost accounting standards
CAS 501 - Consistency in Estimating, Accumulating, and Reporting Costs;
CAS 502 - Consistency in Allocating Costs for the Same Purpose;
CAS 505 - Accounting for Unallowable Costs; and
CAS 506 - Cost Accounting Period.
All costs must be included in the awarded budget, or the cost must be permitted within rebudgeting authority granted by the sponsor
The Principal Investigator (PI), or departmental staff acting on behalf of the PI, is responsible for the review and approval of all transactions. The PI signature, indicating approval, is required on all invoices, purchase requests, and travel expense reports. The KUCR project number or account to charge must also accompany each invoice.
The Business Services department is responsible for assisting PIs and/or their support staff to expend their funding according to generally accepted business practices as well as to determine allowability and allocability to a research project. Business Services also provides guidance and training to ensure compliance.
The Office of Post Award Services is responsible for auditing sponsored project expenditures in accordance with federal and sponsor guidelines by determining allowable and unallowable costs. Post Award Services also provides guidance and training to ensure compliance.
The PI, or departmental staff acting on behalf of the PI, initiates payment by submitting invoices to Business Services or by entering payment vouchers directly into the financial system.
Business Services receives all approved invoices. These are audited and initialed for payment. After approval and clearance by Post Award Services, the payments are made to vendors.