Expenditure Monitoring

Uniform Guidance, 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, provides guidance to be used in determining allowable direct costs of work performed by colleges and universities under sponsored agreements. The purpose of this procedure is to provide guidance to The University of Texas at San Antonio faculty and staff to ensure compliance with Federal, State and University regulations governing the consistent treatment of direct costs to sponsored projects.

Uniform Guidance 2 CFR Part 200 describes 4 factors that can affect the allowability of a cost as it relates to sponsored projects:

• Costs must be reasonable – A cost is considered reasonable if the nature of the goods or services acquired and the amount involved reflects the action that a prudent person would have taken under the circumstances prevailing at the time the decision was made to incur the cost.
• Costs must be allocable to sponsored agreements under the principles and methods of Uniform Guidance Section 200.405 – A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with the relative benefits received.
• Costs must be treated consistently – Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect costs. Where the University treats a particular type of cost as a direct cost on sponsored agreements, all costs incurred for the same purpose in like circumstances must be treated as direct costs or all activities of the institution.
• Costs must conform to limitations or exclusions outlined in Uniform Guidance or in the sponsored agreement as to types or amounts of cost items.

Further, according to the Uniform Guidance Section 200.309 “A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in §200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity.”