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The federal Office of Budget Management has implemented 2 CFR § 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, otherwise known as Uniform Guidance. One of the goals of this transition is to streamline and consolidate the regulations and requirements affecting grants management. Please contact RSP with questions regarding the transition to Uniform Guidance.
Uniform Guidance Subpart D Post-Award Requirements (formerly A-110 Administrative Principles)
All federal funding received directly, or indirectly, must be expended in full accordance with U.S. statutory requirements. The associated programs must comply with all requirements of the federal award.
Uniform Guidance Subpart E Cost Principles (formerly A-21 Cost Principles)
The application of cost principles is based on the fundamental premise that sound management practices will be applied for the efficient and effective administration of the Federal award, and administered in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award.
Uniform Guidance Subpart F Audit Requirements (formerly A-133 Audit Principles)
Non-Federal entities expending $750,000 or more during the entity’s fiscal year must have an audit conducted in accordance with the provisions of Subpart F.
Other Sponsor Specific Guidelines
Guidelines can be accessed at the links below:
Key Personnel Changes
The sponsor needs to provide approval when there are changes in key personnel, such as the effort is being reduced, or an employee’s affiliation with WSU is being terminated, or a new employee is being hired. Please send the changes to the Associate Director of Post Award. Post Award needs the names of the personnel affected in the change and the justification. RSP will follow up with the sponsor for approval.
How to Hire Grant Personnel
If the employee(s) who will be working on the grant is Wright State University personnel, then a Personnel Action Form (PAF) and/or salary reallocation needs to be completed. The PAF is the instrument needed that will directly charge the grant as the employee’s payroll is generated.
If the grant will require filling a new position, then the job posting needs to be completed on PeopleAdmin system. This will generally be initiated by your department administrator. View the compensation salary schedule for research personnel.
Once a new employee is hired either a PAF or and EPAF will need to be completed for the new hire. This will generally be initiated by your department administrator. You can also contact Human Resources for further assistance.
Salary Reallocation is the method used to redistribute past salary from another source of funding to the grant. Salary reallocations should be done within 120 days of the period the salary was earned. Otherwise the salary reallocation may require additional documentation and approvals. Instructions on how to complete the salary reallocation can be found on the WINGS Express Redistributions support page.
How to Hire Student Employees/GRAs
Please see the Career Services Student Employment Supervisors: Post a Job page for instructions on posting and hiring for an undergraduate position.
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The University must follow all federal, sponsor, and institutional guidelines to determine if a cost is an allowable expense.
In addition to being allowable, a cost must meet the following criteria to be charged to a sponsored project:
- Allocable to the project
- Consistently treated
- Necessary for the project
- Compliant with any award restrictions
- Incurred during the project period
Under these principles, costs must be:
- Reasonable: A cost may be considered reasonable if the nature of the goods or services and the amount of cost involved reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made.
- Allocable: A cost is allocable to a sponsored project if (1) it is incurred solely to advance the work under the sponsored agreement; or (2) it benefits both the sponsored project and other work of the institution in proportions that can be approximated through use of reasonable methods.
- Given Consistent Treatment: All costs must be treated the same, whether supported by external or internal funds.
- Compliant: The cost is compliant with any limitations or exclusions set forth in applicable federal regulations and the particular award’s terms and conditions.
Personnel costs (salaries/wages and fringe benefits) should include only Wright State University personnel. Collaborators at other institutions should be included either as consultants/collaborators or within a separate subrecipient budget. Proposed salaries should be in accordance with approved salary scales and position grades, and the budget should reflect the actual percentage of effort that is anticipated. In developing multi-year project budgets, salary increases are included per year.
Note: some sponsors have limitations on the amount of salary that may be charged to a grant (e.g. NIH salary cap). Check the sponsor’s guidelines or RSP for current limitations.
Types of personnel involved on grants may include:
- faculty members, academic year and summer faculty
- research assistants and associates
- postdoctoral researchers
- graduate research assistants
- undergraduate students
- project technical support personnel
- interviewers and evaluators
- Other (specify)
For each person involved in the project, list name (if known), position and percentage of time on the project. RSP includes annual salary increases effective July 1 for fiscal personnel and August 1 for academic year faculty, depending on the start date of the grant. Please contact Human Resources for any questions regarding salaries for new hires.
Calendar Year Information
- Calendar Year: 2080 hours, 260 days
- Academic Year: 1,560 hours, 195 days
- Hours Per Month: 173.33
When personnel salaries are charged, the associated fringe benefits are also charged.
Principal Investigator/Project Director (PI/PD): The person with overall responsibility for the technical and fiscal management of the project.
Co-Investigators: These are other faculty members or other significant individuals who bring specific expertise to the project.
Postdoctoral Researchers: These are usually personnel who have defined pay ranges in HR. See link below for rates.
Other Research Personnel: These are usually research assistants and research associates who have defined pay ranges in HR. See Non-Faculty Research Position Salary Schedule.
Graduate Research Assistants (GRAs): Masters and Ph.D. students may be appointed as GRAs on sponsored projects. See policy regarding maximum hours.
Undergraduate Students: Undergraduate students working on sponsored projects must be paid through student employment at hourly rates. See policy regarding maximum hours.
Administrative Support: The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. Inclusion of such costs on a proposal budget may be appropriate only if all of the following conditions are met.
- Administrative or clerical services are integral to a project or activity.
- Individuals can be specifically identified to a project or activity.
- Such costs are explicitly included in proposal budget or have prior approval from the sponsor.
- These costs are not also recovered as indirect costs.
Other Staff: This category includes technicians, computer programmers, nurses, evaluators, and undergraduate assistants. Identify title, name if known, percent effort, and responsibilities.
Faculty - Full-Time (i.e., 51% FTE or greater)
Faculty (Part-Time, Overload, Summer, Retirees)
Full-Time Unclassified (including Unclassified hourly)
Part-Time Unclassified and Classified Staff
Full-Time Classified Staff
Graduate Research Assistants (GRAs)
May be eligible for tuition remission;
Undergraduate/Graduate Student Hourly Employees
No fringe benefits during academic year.
*Approved DHHS rates
Rate estimates beyond the established year include a 1.5% escalation factor per year.
Fee Remission Policy for Graduate Research Assistants (GRAs)
Office of the Vice Provost for Research (VPR)
Effective Date: Sponsor deadlines on or after July 1, 2021
Tuition for graduate student research assistantships (GRAs) must be directly charged to externally sponsored grants and contracts when the student’s work is specifically tied to the work performed under those agreements.
- When the sponsor allows tuition and stipends as expenses, all new and competitive renewal proposals for funding of research, public service, and instructional activities submitted by the University must include, within the sponsor request budget, the cost of any GRA student stipend(s) at a minimum of $850 per month, and the cost of tuition, for each supported GRA position listed in the proposal. Tuition should be budgeted at the level of in-state tuition cost for full-time WSU graduate students and escalated by 4% per year for multi-year proposed projects.
- If the grant-supported GRA requires out-of-state tuition, the difference between the two rates must be supported by funds provided outside of the VPR’s Office (e.g., the PI’s RIF, college dean’s funds, or the like).
A. Current awards/grandfathering
- Tuition support currently provided to GRAs working under active grants or contracts, or budgeted and approved by the VPR in proposals submitted before July 1, 2021, will be honored to the extent committed and approved in the original sponsor and cost-share budgets or amendments.
If a sponsor does not allow graduate student tuition costs (according to the sponsor’s published guidelines), then other support for the cost (e.g., the PI’s RIF, the college dean’s funds, or the like) must be documented at the time the proposal is routed in Research and Sponsored Programs. The minimum GRA stipend to be charged to the sponsor (currently $850 per month) must be included in the sponsor budget.
Other circumstances may be evaluated on a case-by-case basis.
Salary Increase Escalation Estimate
RSP is currently estimating increases of 3% each year and accumulated annually from that date. The 3% figure is based on average salary increases for the past several years. Individual proposals may use somewhat different escalation factors depending upon the context. For example, if a sponsor limits salary increases to 2% per year, then a 2% escalation factor should be used in proposals submitted to that program.
Contact Career Services for any questions regarding the process for hiring hourly undergraduate and graduate students.
Contact Human Resources for questions related to hiring practices, salary rates, etc.
Capital Equipment (purchased): The University’s definition of capital equipment is an item having an acquisition or donated value of $5,000 or more and a useful life in excess of one year. These items are not subject to Facility and Administrative (F&A) costs when Modified Total Direct Cost (MTDC) calculation is used as the basis for calculating F&A.
Fabricated Equipment: Fabricated equipment is defined as tangible property that is built or assembled from individual parts that cumulatively have an aggregate cost of $5,000 or more. When budgeting for fabricated equipment, components to be purchased for the building or assembling of the fabricated equipment should be budgeted as Capital Equipment Account #794000. This will ensure that the individual charges will not be assessed the F&A rate.
Equipment needs should be itemized and justified in the proposal. Most sponsors rely on the University's definition of "capital equipment" to differentiate between equipment and supply categories.
Travel costs charged to grants and contracts are subject to specific limitations and restrictions, in accordance with terms set by the sponsor. Travel policies of federal and non-federal sponsors vary. Travelers on University trips that are funded directly or indirectly by a federal grant or contract must abide by the federal rules on air travel. All personnel must comply with the Fly America Act for international travel.
Travel costs include expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business related to a sponsored project. Such costs may be charged on an actual basis, or on a per diem or mileage basis in lieu of actual costs incurred subject to the maximum amounts specified by the University and within University Policy 9510 Travel and practices consistently applied to all institutional travel activities. Reimbursement of travel costs associated with sponsored research projects must comply with all provisions stipulated by the sponsoring agency, or with all provisions of the University's travel policy if more restrictive. Funds can be requested for travel to scientific meetings, to conduct fieldwork, to collaborating laboratories and for consultation with the funding agency or with colleagues concerning project research.
Materials and supplies include all consumable materials, including the purchase cost of animals as well as small items of equipment that do not meet the threshold for "capital equipment." Each item or group of items should be listed and carefully justified.
Note that federal sponsors do not allow general office supplies unless their use is above and beyond what would be provided through F&A and can be specifically justified for the project.
Computing devices, defined as supplies where the cost is the lesser of the WSU capital equipment threshold of $5,000, are allowable for devices that are essential and allocable, but not solely dedicated to the performance of an award. The computing devices must be included in the budget and justified in the budget justification that is submitted to the sponsor.
Participant support costs are those costs paid to (or on behalf of) participants or trainees (not employees) for participation in meetings, conferences, symposia, and workshops or other training activities, when there is a category for participant support costs in the award. Registration fees, travel allowances, manuals and supplies, tuition and stipends may be regarded as participant support costs in this case.
Other direct costs may be used for other project expenses that do not fit into the above classifications. Examples include publication costs, computer services, human subject participation fees, patient care, participant support, repair and maintenance of proposed equipment purchases, rent and utility expenses, animal services, communication costs, tuition, and some types of telephone service.
Facilities and administrative (F&A) costs (formerly known as indirect costs) are incurred in conducting or supporting research and service but they cannot be readily identified as benefiting particular research or service projects. View additional details on what is considered F&A.
Wright State University maintains a federally negotiated F&A rate agreement that applies to a proposal budget’s modified total direct costs, which consists of the following: all salaries and wages, fringe benefits, materials, supplies, services, travel, and subgrants and subcontracts up to the first $25,000 of each subgrant or subcontract (regardless of the period covered by the subgrant or subcontract).
Effective 7/1/2017 through 6/30/2024, Provisional 7/1/24 until amended
Organized Research, On-Campus: 50%
Organized Research, Off-Campus: 26%
Other Sponsored Activities, On-Campus: 37%
Other Sponsored Activities, Off-Campus: 26%
Instruction, On-Campus: 50%
Instruction, Off-Campus: 26%
Modified Total Direct Costs (MTDC) are the sum total of a projects direct costs, but excludes the following direct cost items:
- The portion of each individual subgrant and subcontract in excess of $25,000. An individual grant or contract may include several subgrants or subcontracts
- Equipment with an estimated life of one or more years and an acquisition cost of $5,000 or more per unit
- Arrangements under which federal financing is in the form of loans, scholarships, fellowships, traineeships or other fixed amounts based on such items as education allowances or published tuition rates and fees of an institution
- Patient care charges
- Tuition remission included as a direct cost
- Rental costs of off-site facilities
- Capital expenditures
- Participant costs
The MTDC base will be applied on all proposals, unless specific sponsor guidelines state otherwise, or the project is eligible for rate exceptions (University Policy 6340.3).
It is important to review the program guidelines as many sponsors indicate what costs, including F&A, are or are not allowable. When applying less that the full F&A rate, a copy of the sponsor's guidelines is required to be provided to RSP.
The federal government provides guidance on items that are considered unallowable costs. The list below includes examples of some but not all unallowable costs.
- Advertising and public relations (except costs incurred for recruiting personnel required as part of a sponsored project)
- Alcoholic beverages
- Alumni activities
- Bad debt (including collection costs and related legal costs)
- Donations and contributions
- Entertainment costs (including food)
- Fines and penalties
- Goods or services for personal use
- Interest expenses (including interest incurred on borrowed capital, temporary use of endowment funds, or the use of the University’s own funds)
- Membership to civic or community organizations
- Proposal costs (e.g. time and effort, printing and postage, etc.)
The budget justification is a narrative document that defines how the requested and cost-shared amounts were calculated and explains how each cost is related to the project’s goals and objectives. The contents of the budget justification should include any information elements required by the sponsor.
Budget Justification Examples
NSF budget justification example:
Cost sharing is defined as charging part of the costs of a sponsored project to a source other than the sponsor. This is sometimes referred to as matching funds. Voluntary cost sharing should be minimized whenever possible.
Types of Cost Sharing:
- Mandatory Cost Sharing
Mandatory cost sharing is required by the sponsor in the program announcement. “Mandatory” refers to those costs that are required to be contributed by the University as part of the award.
- Examples: In some cases, the applicant must provide an amount equal to the sponsor’s funds, i.e., a one-to-one match. In other situations the sponsor will specify a percentage of participation in such costs (e.g., sponsor will provide funds not to exceed 75% of total project costs).
- Voluntary Committed Cost Sharing
Voluntary committed cost sharing is NOT required by the sponsor, but is quantified in the proposal budget or budget justification. In general, University resources should not be offered unless required; however, there are disciplines and sponsors where such voluntary cost sharing may enhance the competitiveness of proposals. Voluntary cost sharing commitments in a proposal that is funded become a condition of the award agreement and must be fulfilled.
- Examples: Providing a cost share budget or budget justification to the sponsor showing a percent of effort higher than the sponsor is paying and/or details on additional salary, fringe, and F&A amounts that are not paid by the sponsor. (If awarded, the cost share total committed will need to be tracked by Post Award as part of the award and reporting process, if the sponsor requires it.)
- Voluntary Uncommitted Cost Sharing
Voluntary uncommitted cost sharing is NOT required by the sponsor, and is NOT quantified in the proposal budget or narrative. In general, University resources should not be offered unless required; however, there are disciplines and sponsors where such voluntary cost sharing may enhance the competitiveness of proposals.
- Examples: Unrecovered F&A over the sponsor’s allowable F&A rate, tuition, salary over the NIH cap, contributing more effort on the project than the amount of support requested from the sponsor (i.e. cost share not reported to the sponsor).
Sources of Cost Sharing Funds
Any contributions that use University funds are considered cash cost sharing for the purposes of documentation and reporting. Outside collaborators may also provide cash funds for cost share.
- In-kind or Third Party
In-kind contributions are “donations” of services (professional, technical or consultant), supplies, equipment or cash from a source outside the university. These third party contributions must be integral to and necessary for the project or program, and their value must be reasonably determined.
Unallowable cost share
- Cost sharing of summer salary for academic year faculty is not allowable unless a source of departmental funds has been identified and approved during the budget development process.
Subcontracts on Grants
A subcontract should be budgeted for at the pre award stage and include the Statement of Work (SOW), subcontract budget and subcontract contact information. The Grants Accountant will issue any subcontracts budgeted at the time the award is processed. Wright State can only authorize funding and time to the subcontractor to the extent Wright State has received funding and time from the prime sponsor.
How to Hire a Consultant
Your grant may provide for hiring a consultant to perform certain duties in relation to your grant. To determine whether or not the individual should be hired as an employee or a consultant, view information on the Controller's Office Forms and Resources page.
View the guidelines to be followed in contracting with this individual. View a copy of WSU’s Consulting Agreement on the Office of Strategic Procurement's Forms and Links page.
Travel on a Grant
Wright State University’s Travel Policy is outlined in University Policy 9510 Travel.
ALL federally funded travel must comply with the Federal Travel Regulation, and the U.S. Fly America Act; a United States flag carrier MUST be used for this travel. Therefore, all foreign travel on grants must be approved in advance by The Office of Research and Sponsored Programs (RSP). Use Banner account code 746900 to complete the FOAP on all Travel Authorization (TA) forms and submit the TA to RSP for approval along with the flight itinerary. Upon returning from the foreign travel, the Travel Expense Report must be approved again by RSP.
Under most awards, supplies and equipment are owned by the university. Some awards, particularly federal contracts, have specific guidelines for purchases of supplies or equipment, and may even require approval from the sponsor for such purchases if they were not listed in the approved budget. If you need assistance interpreting the terms and conditions of your grant or contract, please contact RSP. To initiate requisition activities: Access WrightBuy.
If the sponsor allows for the purchase of capital equipment, it will be indicated in the awarded budget as account 794000. Capital equipment includes all movable items that have a probable useful life of two or more years, have an original cost of $5,000 or more (either for a single item or fabricated equipment – individual parts that cumulatively have and aggregate cost of $5,000 or more), and are neither permanently attached to a building nor its utility systems nor incorporated into the building at the time of initial construction nor during later modifications. The total cost includes all expenditures incurred in acquiring the equipment and preparing it for use. This would include the purchase price, freight & handling charges, insurance on the equipment while in transit, the cost of special foundations required assembly and installation costs, and the cost of conducting trial runs.
Visit the Controller's Office Capital Equipment page for complete information on the purchase of equipment.
Supplies that support the technical substance of the grant are generally allowable expenses. Office supplies (e.g. paper, pens, toner & ink cartridges, etc.) are not an allowable expense on a grant. These may serve as general use items and support an administrative purpose rather than the technical substance of the grant and should be charged to the fund that receives the F&A generated by the grant. If it can be demonstrated that such items are necessary to perform the technical aspects of a grant, the expense may need to be reclassified to the appropriate expense account within the grant. If a journal voucher is necessary to reclassify or transfer the expense, the document text of the JV should adequately clarify how this purchase supports the technical substance of the grant and is not for administrative purposes only.
It may be necessary to transfer an expense from one source of funding to a grant, or from one account to another account within a grant. This is accomplished by submitting a Journal Voucher (JV) in WINGS Express. Keep in mind that you may only use a JV to transfer costs that begin with accounts 7xxxxx (not labor costs that begin with accounts 6xxxxx). Expense transfers should be done within 120 days of the original expense. If expense is transferred more than 120 days after the original expense, additional documentation and approvals may be required.
More information regarding JVs can be found in the:
Additionally, you will find complete instructions in Chapter 4 of the WINGS Express Finance Documentation.