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Wisconsin Partnership Program Policy on Allowable and Unallowable Grant Expenses BACKGROUND The Wisconsin Partnership Program (WPP) has specific policies on allowable and unallowable expenses for programs and projects it funds. WPP staff review all proposed expenditures and discuss any questions or concerns with the applicant or grantee. DEFINITIONS Allowable Costs: The WPP allows expenses directly incurred by the grantee as outlined in the budget of the approved application. All project budgets must successfully pass a technical review by WPP financial staff. The grantee must be able to specifically identify project expenses associated with the WPP grant award. Unallowable Costs: The non-supplanting stipulation requires that all reimbursable expenses be directly attributable to the grant and that WPP funds cannot replace other funding the grantee organization is receiving. Examples include: overhead pre-award costs alcoholic beverages proposal costs entertainment donations fines any expenses for goods and services for personal use of employees lobbying Because of non-supplanting requirements, the WPP does not allow indirect costs, such as overhead or administrative costs. The WPP requires that grantees have existing infrastructure in place to provide indirect support for the grant agreement. Grantees must indicate their capacity to oversee and manage the project, programmatically and financially, before any funding decisions are made. Overhead is not an allowable expense, even if an existing cost allocation model exists. Expenses for existing clerical and administrative staff such as book keepers or accountants are considered an indirect cost unless a new position has been created for the sole purpose of managing the WPP grant. POLICY ALLOWABLE COSTS Expense Item Advertising Audit Books, Journals and Subscriptions Revised 2/10/2016 Allowable Advertising for personnel recruitment, purchase of goods or sale of surplus materials is allowable if specifically related to the project, such as recruitment of dedicated personnel. Grant funds may be used to support a program specific audit in the absence of a routine organizational audit. Books, journals and subscriptions to professional and technical publications are allowable if specifically related to the project. Unallowable (Indirect) A review of financial controls by an external audit firm is considered a broader organizational expense that cannot be specifically attributed to the WPP project and is not allowable. Wisconsin Partnership Program Policy on Allowable and Unallowable Grant Expenses Expense Item Consultant Equipment Allowable Consultant services – an individual or firm hired to perform professional, short-term services – are allowable if specifically related to the project. Equipment is tangible personal property with a useful life of more than two years and a unit cost greater than or equal to $5,000. Unallowable (Indirect) Special purpose equipment – scientific equipment used only for technical activities –is allowable as a direct cost if specifically related to the project. General purpose equipment – computers, office equipment, and furnishings, which are not limited to research or technical use would be allowable if directly used for the grant. Fundraising Honoraria Meals and Meeting Refreshments Memberships and Dues Office Supplies Revised 1/10/2017 With prior approval by the WPP, development activities are allowable so long as they are related to the grant, outlined in the project work plan and contribute to sustainability of the goals of the project. Honoraria, such as a speaker’s fee, are allowable if specifically related to the project with approval by the Wisconsin Partnership Program. Meeting refreshments, site visit meals and guest meals are allowable if specifically related to the project. Meals associated with staff travel, conference or symposia are allowable but are subject to limitations established by the organization. Only memberships and dues specifically related to the project are allowable with approval by the Wisconsin Partnership Program. Office supplies – those items usually maintained in a departmental stock for general use by all staff, including pens, pencils, writing paper, file folders, departmental letterhead, envelopes, staples, staplers and rulers – are allowable if specifically related to the project. 2 Recreational activities, either for entertainment or team-building, are not allowable. A general allocation of office expenses would be considered indirect cost and not allowable. Wisconsin Partnership Program Policy on Allowable and Unallowable Grant Expenses Expense Item Participant Support Costs Patient Care Supports Personal Computers Postage/Messenger Service Professional Services Public Relations and Marketing Recharge Center Cost Rent Revised 1/10/2017 Allowable Participant support costs (PSC) are small payments to individuals who participate occasionally in research, education, or community-based programs. This may include stipends paid to, or on behalf of, participants or trainees (but not employees) in connection with official meetings, conferences, or symposia, training or research projects. These costs are allowable with WPP prior approval and in accordance with the PSC Guidelines. Payments may be in the form of gift cards or other non-cash items or incentives. Cash may not be used. A $50 incentive limit per occurrence applies for nonresearch related participation. Clinical services that involve screening and education, or mobilizing resources to promote healthcare access are allowable. The purchase of personal computers is allowable if specifically related to the project. Postage – routine postage costs –is allowable and shipping of materials, receiving goods for project use or other delivery of items are allowable if directly related to the project. Individuals or companies hired to perform professional, short-term services, such as accounting or legal services, are allowable if specifically related to the project. Public relations and marketing costs are allowable if specifically related to the project. The operating costs of a unit (photocopy service, stockroom) that provides routine goods and services within an organization are allowable if specifically related to the project. Rental costs – cost to lease building space or equipment – are allowable if specifically related to the project and they represent a new cost solely attributable to the project. 3 Unallowable (Indirect) Patient care with the sole purpose of providing clinical services related to treatment or follow-up for specific health conditions is not allowable. General costs, such as corporate legal or accounting services, are generally indirect costs and not allowable. General rental costs such as allocation of preexisting office space is indirect cost and not allowable. Wisconsin Partnership Program Policy on Allowable and Unallowable Grant Expenses Expense Item Salaries and Fringe Benefits: Administrative and Clerical Personnel Allowable Such expenses are allowable only if specifically related to the project and represent a new cost incurred. Salaries and Fringe Benefits: Technical and Programmatic Personnel Salaries and fringe benefits for technical and programmatic personnel staff – personnel performing scientific or other technical work related to a project – are allowable if specifically related to the project. The purchase of computer software is allowable if related to the project. Operating units that use specialized equipment or technical expertise to provide goods or services for a fee are allowable if specifically related to the project. Costs of student publications and activities are allowable if specifically related to the project. Equipment and service costs for local telephone, fax service and pagers are allowable if specifically related to the project. Costs incurred due to early termination of a project agreement are allowable so long as effort is made to minimize those costs by canceling contracts and reselling surplus goods. Travel – transportation, lodging, subsistence and related costs for official business, in accordance with organizational policy – is allowable if specifically related to the project. UW graduate students under the direction of a Principal Investigator who are directly working on the project and being funded by the project may incur tuition remission charges, which are allowable. Software Specialized Service Facilities or Service Center Student Publication and Activity Costs Telephone, Fax Lines and Pagers Termination Costs Travel Tuition Revised 1/10/2017 4 Unallowable (Indirect) Salaries and fringe benefits of general corporate or organizational support staff – departmental administration, including professional and clerical staff, and central administration staff serving the entire organization – are normally considered an indirect cost and not allowable. Individual employee tuition reimbursement is not allowable Wisconsin Partnership Program Policy on Allowable and Unallowable Grant Expenses UNALLOWABLE COSTS Expense Item Alcoholic Beverages Alumni Activities Bad Debts Commencement/ Convocation Contingency Funds Defense, Prosecution, Claims and Appeals Depreciation Donations and Contributions Entertainment Fines and Penalties Goods or Services for Personal Use by Employees Institutional Review Board Fees Insurance Interest Investment Management Lobbying Losses on Project Agreements Maintenance and Repair Payroll Fees Pre-Award Costs Proposal Costs Sales Taxes Scholarships Revised 1/10/2017 Description Alcoholic beverages are not allowable. Alumni relations and alumni service costs are not allowable. Losses from uncollectible accounts, collection costs and related legal costs are not allowable. Costs of ceremonies and receptions are not allowable. Provisions made for events that are uncertain as to actual occurrence, timing or extent are not allowable. Defense, prosecution, claims and appeals are not allowable. The cost of an asset – building or equipment – spread over the asset’s useful life is not allowable. Donations and contributions at a fundraising event, including gifts, memorials and purchase of tables, are not allowable. Amusement, social activities, and related costs, including tickets, meals, lodging and gratuities, are not allowable. Costs resulting from violations of laws and regulations are not allowable. Items or services providing direct personal benefit to employees are not allowable. Costs associated with obtaining necessary approvals from research compliance bodies, such as the Institutional Review Board, are considered institutional costs and are not allowable. In fact, IRB fees are waived for WPP grantees. Insurance coverage for normal business purposes, whether provided by an external company or through a self-insurance program, is not allowable. Interest expense is considered an institutional cost and not directly allocable to a project. Costs for investment management are not allowable. Attempts to influence outcomes of elections or other political actions are not allowable. Costs in excess of available funding are not allowable as a direct cost on subsequent project agreements. Costs to keep property in generally efficient operating condition are not allowable. Fees for payroll processing and maintenance are considered a broader organizational expense that cannot be specifically attributed to the WPP project and are not allowable. Pre-award costs – costs incurred prior to the start date of the project agreement are not allowable. Expenses related to the preparation of the proposal, including typing, copying and mailing costs, prior to the grant award are considered institutional costs and are not allowable. State sales taxes paid by tax-exempt organizations or tax exempt entities are not allowable and will not be reimbursed. Scholarships are not allowable. 5