Buying Computers on Awards under the Uniform Guidance

By Bruce Morgan posted 03-24-2015 11:11

  

Buying Computers on Awards under the Uniform Guidance

Care to comment on the following DRAFT guidelines created by Case Western Reserve University and the University of California, Irvine?

 Purchasing Computing Devices with Federal Funds (applicable Uniform Guidance Sections 2 CFR Part 200.20 and 200.453)

Computing devices are machines used to acquire, store, analyze, process, and publish data and other information electronically and include accessories (or peripherals) for printing, transmitting and receiving, or storing electronic information.  Computing devices costing less than $5,000 are not considered equipment and therefore are treated as supplies and materials.  Therefore, if a computing device is to be acquired for use in the performance of a federal award, the computing device may be charged to the federal award provided that:

·         it is essential (i.e., necessary) to performing the work under the award, and

·         the cost is allocable and reasonable.

Determining whether a computing device is essential – The Principal Investigator should consider (and document) whether performing the work under the award without the computing device would be difficult and inefficient.  An important measure of this is determining (and documenting) whether the anticipated cost of performing the work without the computing device is greater than the combined cost of performing the work plus the cost of acquiring the computing device. 

Determining whether a computing device is allocable to a federal award – If a computing device is essential to a federal award it is allocable to that award.  The total cost may be allocated to the benefiting federal award – even when its usage is not solely dedicated to the award.   However, before doing so, the Principal Investigator should first consider and use other reasonable cost allocation methodologies provided that an alternative methodology will (without undue effort) result in a higher degree of accuracy in cost allocation.

Determining whether the cost of a computing device is reasonable – The Principal Investigator must make an informed, prudent decision taking into considering not only the cost, but the utility, quality and value of the device to the project.

If a computing device is not essential to a federal award, it is not allocable (in whole or in part) as a direct cost to that award.  In such cases, the computing device is considered to be a “general use” item and must be treated as an indirect cost expense (just like paper, pens and other general use supplies) and charged to an appropriate institutional funding source.

Please remember that all expenses charged to federal awards must conform to the cost principles specified in the OMB Uniform Guidance.  Please consult with the Office of Research Administration if you should have any questions about whether you may charge a specific expense to federal funds.

Suzanne M. Rivera, Ph.D., M.S.W., Vice President for Research, Office of Research and Technology Management, Case Western Reserve University

Bruce Morgan, Assistant Vice Chancellor for Research Administration, University of California Irvine Office of Research

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04-27-2015 12:18

Thanks, Sue and Bruce, for this excellent discussion.

04-23-2015 09:13

Great job guys. Would you want to include anything in the policy that explicitly speaks to unlike circumstances? If every faculty member gets a computing device by virtue of his/her employment status, is the essential/reasonable/allocable threshold sufficient to direct charge to a grant?

03-25-2015 10:19

I'm sure it goes without saying too that I would establish that all PIs requesting items that need added justification write it out a submit it to the appropriate OSP official for added documentation. This can than be "approved" and put on file with the grant documents. Always better to get the justification upfront at the time of purchase than to try to get it after the fact. Well done Bruce and Suzanne!