Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

Allowable "Late-In-Period" Expenses

Stewardship and Compliance

Expenses for the acquisition of materials and supplies late in the project period (within 60 days of the project "end date") will routinely be scrutinized to assure that the expense is allowable and allocable. While such expenses may be completely appropriate, they will be reviewed to assure that unspent project funds are not being "used up" with acquisitions which do not benefit that project.

One key to the allowability of these expenses is proper documentation. This includes a written statement from the Grant or Contract (administrative) Officer authorizing the expenditure. E-mail is usually acceptable for grants, but an actual signature may be needed for contracts. In all cases, a copy of the authorization should be kept with the project records.

Here are some real situations:

The last-minute photographer

A University staff member conducting a postaward review of project expenses noticed that an expensive camera was purchased at the very end of a grant project period. The camera had unique capabilities related to the research being conducted, but appeared to be acquired too late to be of any benefit to the project that paid for it.

The PI explained that the technical monitor suggested that the University use the remaining funds on the grant to acquire this important piece of research equipment. The sponsor wanted to see its funds used to advance work in this area, and the camera was a good way to do that.

What the PI did NOT do in this example was get the written authorization of the Grant Officer for the acquisition. Upon the suggestion of the staff member, the PI sent an email to the Grant Officer, and got an "okay" in return. In this case, the expense of the equipment was allowed, but, if the reply from the Grant Officer has been different, the cost could have been disallowed, and the PI would have had to fund the camera with her own department funds.

The final frontier

The PI knew that such an acquisition would be questioned for at least two reasons: it took place late in the project, and was for a piece of "general purpose" equipment.

The PI sent a request to the Grant Officer reminding him that, in order to complete the final report for this project, a particularly intensive amount of data analysis would be necessary. The approved project budget included funds to purchase a desktop computer especially for this analysis. The amount of work to be done, and the timeframe in which it had to be accomplished, made it impractical to use existing department equipment for this task.

The Grant Officer responded with concurrence, and the PI gave a copy of the message to the OSR Contract Officer to keep with the project files.

The purchase of the computer was allowable, allocable and reasonable, and therefore appropriately charged directly to the project.