I would agree with John's sentiments, especially when you read what it says about materials and supplies in the latest version of A-21. It says "only materials and supplies actually used for the performance of a sponsored agreement may be charged as direct costs." While this isn't equipment per se, I would apply the same rationale for equipment purchases. Pat Patricia A. Hawk Cost Analyst, Business Affairs Oregon State University 306 Kerr Administration Building Corvallis, OR 97331 (phone) 541-737-9585 (fax) 541-737-2069 -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Baumann, John Sent: Sunday, January 23, 2005 8:18 PM To: xxxxxx@HRINET.ORG Subject: Re: [RESADM-L] Timing of Purchases I would address the question slightly differently -- We are very hesitant to approve the purchase of equipment or even certain supplies at the end of a grant. In most cases, how could the equipment be used in support of the funded scope of work if the project period is ending or has ended -- assuming there was not a competitive continuation in the pipeline or something? It has been my experience, as well, that most funding sources look at this with something of a wary eye and of questionable consistency with the letter and/or spirit of the award. While there are of course exceptions in which case the purchases are appropriate -- in too many cases it could simply be an interest in spending whatever funds remain without due attention to the terms and conditions of an award. . John John R. Baumann, Ph.D. Associate Vice Chancellor for Research Director, Office of Research Services 5100 Rockhill Road (US Postal Service) 5211 Rockhill Road (Courier Service) Kansas City, MO 64110 816.235.1303 (v) 816.235.6532 (f) -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Ted Mordhorst Sent: Thursday, January 20, 2005 9:21 AM To: xxxxxx@HRINET.ORG Subject: Re: [RESADM-L] Timing of Purchases 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") ====================================================================== ====================================================================== 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") ======================================================================
