Guidance on general purpose purchases using sponsored funds

From: Office of the Vice Chancellor for Research
Sent: Tuesday, May 30, 2023, 8:53 a.m.
To: KU principal investigators

The Office of Research is committed to continuously improving our internal processes. Recently, we have received questions about general use supplies and sponsored research funding. 
 
General purpose expenses such as office supplies, cleaning supplies and computing devices are typically considered indirect costs according to Uniform Guidance and KU's cost accounting policy because they often can't be easily or accurately identified to benefit a specific award or directly assigned to sponsored project activities. KU has compliance obligations, and federal auditors often choose these types of expenses for audit review to ensure they are allowable, correctly allocated, and adequately justified and documented. A general rule is that any item which might be considered an “office,” “cleaning,” or “general use” supply to someone unfamiliar with your research would fall into this category and should be purchased with an F&A account or another nonsponsored funding source. Federal agencies may consider this type of charge on a sponsored project a duplication of cost because F&A is intended to cover general use supplies.
 
Unallowable per KU’s cost accounting policy:   

  • Paper 
  • Toner 
  • Pens
  • Staples 
  • Folders
  • Markers 
  • Postage
  • Local telephone costs


Allowable with additional justification 

However, there are times when these types of supplies are directly related to your research and can be allowed with additional justification. In these cases, please adhere to the following guidance for your purchase:  

  1. If the item is directly used for the specific project — and only for the project — during the project period, include a brief justification of how it will be used and how it directly benefits the project. 
  2. Items that will be used for more than one project can be split funded or allocated between different funding sources. Include a justification for how they will be used and how they will benefit each project. Additionally, state how you calculated the funding split. 

The Office of Research is streamlining our expenditure review processes to minimize the need to contact PIs for additional information. Providing the justification along with the receipt will expedite the process. PIs should expect to receive questions from our office initially, but we anticipate fewer questions as the process improves.
  

Including supplies in proposals

For future projects, if you expect to incur these types of expenses, they should be included in your proposal to the sponsor. When proposing a scope of work that necessitates purchasing these types of items, the budget justification submitted to the sponsor must enumerate these items explicitly, along with an explanation of how these costs can be reliably allocated to the proposed project. Such a description provides the sponsor with the opportunity to review and approve these types of costs being charged directly to the project. Simply referring to the costs as "research supplies" in the justification is insufficient for meeting this requirement. As a reminder, computing devices must be essential and allocable in order to be charged directly; but according to Uniform Guidance, they no longer need to be solely dedicated to a particular project. 
 
Some examples of general use supplies that could be allowable if listed in the approved budget or with additional justification:  

  • Cleaning supplies (multipurpose cleaner, glass cleaner, sponges) 
  • Paper towels 
  • Lab notebooks
  • Razor blades
  • Tape
  • Trash bags
  • Utility/multipurpose lighters
  • Glue sticks
  • Batteries
  • Plastic wrap
  • Computers/laptops 

 
For questions about preparing a comprehensive proposal budget justification, please contact Pre-Award Services. Your AMS contact can respond to questions about charges on existing awards.