Allowable
"Late-In-Period" Expenses
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Expenses
for the acquisition of materials and supplies late in
the project period (within 90 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 may be reviewed to
assure that unspent project funds are not being "used
up" with acquisitions that do not benefit that project.
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One
key to the allowability of these expenses is proper
documentation. This documentation is in the form of
a written justification to be attached to the purchasing
requisition or placed in the departmental award file.
Here are some real situations:
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The
last-minute photographer
A UR internal auditor 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 UR 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.
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What
the PI did NOT do in this example was to include a written
justification in the award file as to why the purchase
was made. In this particular case, it may have also been
prudent to get the written authorization of the sponsor's
Grants Officer for the acquisition. Usually, the
sponsor will not provide approval for "late"
purchases and will leave the decision with respect to
allocability to the grantee. In this case, a confirmation
from the Grants Officer would have been appropriate.
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The
final frontier
A project involves a series of experiments and data analysis.
At the end of the project period, the PI authorized the
acquisition of a desktop computer.
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, therefore, included a written justification with
the purchase requisition that stated 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 purchase of the computer was allowable, allocable
and reasonable, and therefore appropriately charged directly
to the project. |
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