In cases like this I invoke the "reasonable" and "allocable" principals from
OMB Circular A-21. Is it reasonable to state that the supplies and
equipment will be used to further the work under the sponsored agreement?
In most situations the answer is probably not, however for some federal
agencies the "end date" is often not really an end date but a milestone date
or end of a funding period. Most federal agencies allow for the inclusion
of "unliquidated obligations" in the award expenditures. The definitions of
the term unliquidated obligations that I have seen do not include a
statement that the goods are received, only that the obligation is incurred
prior to the expiration date of the award. In the NSF GPM 602.3
Post-Expiration Costs section it states:
"NSF funds may not be expended subsequent to the expiration date of the
grant except to liquidate valid commitments that were made on or before the
expiration date. (See GPM 452, "Final Disbursement Reporting," and GPM 617,
"Publication, Documentation and Dissemination".) For example, commitment of
project funds is valid when specialized (research) equipment is ordered well
in advance of the expiration date but where, due to unusual or unforeseen
circumstances, delivery of such equipment is delayed beyond the expiration
date. The costs of equipment ordered after the expiration date, however, may
not be charged to the project."
In discussing this subject with the DHHS OIG I learned that they do not
consider the end of a funding period, (non-competing or competing) to be the
expiration date of the grant. Therefore they would consider the date the
"obligation" was incurred rather than the date received to be the
determining factor in allowability for a funding period. In other words, if
an item was ordered prior to the end of a funding period but the bill is not
paid until the following funding period it is an unliquidated obligation to
the prior funding period without consideration to the receipt date. They do
consider the receipt date of items at the terminal end of the grant and
would disallow items received after that date. So if there is a question of
the award being continued on a competing renewal it is advisable that
expenditures be treated as if it is the terminal end of the grant.
I hope this helps. Give me a call if you would like to discuss this
further.
Ted Mordhorst
Assistant Director for Compliance
Grant and Contract Accounting
University of Washington
3905 University Way NE
Seattle, WA 98105-6692
206-616-8678
xxxxxx@u.washington.edu
----- Original Message -----
From: "Debra Leonard" <xxxxxx@KENT.EDU>
To: <xxxxxx@HRINET.ORG>
Sent: Thursday, January 20, 2005 6:07 AM
Subject: [RESADM-L] Timing of Purchases
>I was wondering if other universities have a policy concerning the timing
> of purchasing supplies and equipment on a grant. What do you do if a PI
> orders supplies and equipment before the grant end date, but it is not
> delivered until after the grant ends. If the equipment is received after
> the grant end date, would you charge the equipment to the department?
>
> Thanks for any input you can provide.
>
> Debra Leonard
> Mgr. Accounting
> Kent State University
> Grants Accounting
> phone #330-672-0988
> fax #330-672-8328
> e-mail: xxxxxx@kent.edu
>
>
> ======================================================================
> Instructions on how to use the RESADM-L Mailing List, including
> subscription information and a web-searchable archive, are available
> via our web site at http://www.hrinet.org (click on "Listserv Lists")
> ======================================================================
>
======================================================================
Instructions on how to use the RESADM-L Mailing List, including
subscription information and a web-searchable archive, are available
via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================
