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During a workshop I recently attended, hosted by the National Council of University Research Administrators (NCURA), the presenter covered the topic of “allowability.” In this interactive workshop, the speaker presented scenarios to consider regarding whether or not a charge could be allowable on a project. I was surprised by the variety of perspectives and solutions that participants offered. This illustrated to me that sponsored research administration resides solidly in the area of “it depends.” “It depends” on the nature of the research, the scope and statement of work, sponsor requirements, and university regulations. For CU ��«����Ƶ, many times the guiding regulations are our Cost Principles which were developed as a collaborative effort between departments and central offices.

Many of the scenarios that were presented during the conference relied on the concept of “like and unlike circumstances.” If you haven’t already, I suggest reading our Cost Principles Procedure on Like and Unlike Circumstances. Then consider the following example with which the attendees grappled:

Example Scenario

Scenario 1: A PI (non-CU) requested reimbursement for replacement tires on a personal vehicle which was used for an archeological research grant. The university’s policy states that the most cost-efficient means of transportation should be utilized, and rented through university transportation services. Can this reimbursement be allowably charged to the grant?

Solution: The PI’s university did not offer an adequate vehicle, in this case with off-road, four-wheel drive capabilities, which was necessary to access research sites at multiple locations over the course of an entire summer. The DRA researched the cost to rent a similar vehicle from an external vendor and found it to be greater than the cost of the replacement tires. Additionally, based on further input from their central office, they determined the remote locations were “unlike” locations considered when the policy was written. Therefore, all parties involved determined the expense was allowable as a direct cost on the grant because it represented an “unlike” and justifiable circumstance furthering the scope of work.

Making the Lesson Real

If this was a scenario at CU ��«����Ƶ, the PI or DRA would recognize this as a potentially unallowable expense. The Cost Principles are one source of guidance, though some scenarios should be treated on a case-by-case basis. In this case, a grant accountant or closeout accountant would have been involved to provide additional guidance.

Throughout the life of any project, though especially as the end date approaches, DRAs in coordination with SPA, can proactively review expenditures to assess whether or not the costs are allowable and we have appropriate documentation.

The Lesson I Learned

To successfully manage any sponsored project, all parties must work collaboratively. This is especially true when the initial solution is “it depends.” As each party fulfills their role, we also support one another to fully vet the circumstances. This helps protect our university and our research. We are one team working together toward the same goal.