OMB Circular A-21, entitled “Cost Principles for Educational Institutions”, is the primary document which sets forth federal requirements related to charges to grants and contracts. This document provides guidance on direct charges to sponsored projects as well as the calculation and application of the indirect cost rate (now referred to as Facilities and Administration, or “F&A”).
OMB Circular A-110, entitled “Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations”, establishes the principles by which a federal agency must conduct business with non-profit institutions, including pre-award and post-award requirements, property, procurement and other standards for financial management systems.
Various Policy Statements issued by individual agencies, like the NIH and PHS Grants Policy Statements
NSF Grant Policy Manual (Terms and conditions included on the grant award or contract document.)
There are a multitude of local government as well as voluntary agencies that award grants and contracts to the University. Each of those agencies has their own rules governing the use of those awards. Many of those documents are available from CU's Sponsored Projects Administration.
The various University policies concerning the administration of sponsored projects can be found in the University Administrative Policy Library.
General Policy Overview
All of the University’s policies governing expenditures also apply to grants and contracts. These policies include those related to procurement, human resources, accounts payable and payroll.
Additionally, the Office of the Controller has developed a number of policies specific to grants and contracts. These policies include guidance on what costs may not be charged to sponsored projects.
OMB Circular A-21 contains specific language which precludes or limits charging certain expenses to federal grants and contracts. These expenses include specifically unallowable costs, clerical and administrative salaries, and office supplies.
Specifically unallowable costs include the following expenses, which may never be charged either directly or indirectly to a Federal grant or contract:
Membership in non-professional organizations
First & business class travel (coach class or its equivalent can be charged)
Consult Controller’s Office Policy for Segregation of "Unallowable" Expenses, for a detailed explanation and listing.
Clerical and administrative salaries generally may not be charged directly to grants and contracts. There are important exceptions to this rule. Consult Controller’s Office Policy Statement Charging Administrative and Clerical Salaries to Federal Grants and Contracts, for detailed explanation and institutional policy.
Office expenses, such as postage, office supplies and local telephone calls, generally may not be directly charged to grants and contracts. There are important exceptions to this rule. Consult Controller’s Office Policy Statement Charging Office Supplies and Other Administrative Expenses (other than salaries) to Federal Awards, for further information.
Gifts (i.e. NOT grants)
For internal parties interested in more information about CU Gift Policies, go to UDARNet at http://wwwb.ais.columbia.edu/udarnet/index2.jsp and Log in, Click on "How Do I ... Work with Gift Systems?" then select "Policies, Procedures and Best Practices",which will take you to an index of topics. For determining whether funding should be considered a gift or a grant, contact Sponsored Projects Administration.