Forms, Policies & Procedures

Cost Sharing Policy

1. POLICY
   The University engages in cost sharing when it is in the best overall interest of the University, limited to situations in which it is mandated by the sponsor per solicitation or policy guidelines, or deemed appropriate in light of specific and compelling circumstances.
2. SCOPE OF POLICY
   This policy establishes the requirements and procedures for proposing, approving, administering, and documenting Cost Sharing on Sponsored Projects, including all contributions, such as cash and in-kind, that a recipient makes to an award at the University of Delaware (“UD” or “University”). This policy also sets forth requirements to ensure compliance with federal regulations (Office of Management and Budget (OMB) Circulars A-110 and A-21 or Uniform Guidance 2 CFR 200). This policy applies to all University departments, units, faculty, staff and students.

Related Links

Cost Share for Equipment Policy

The complete policy and more can be found on the General Counsel’s web site.

Debarment Statement

This form is used to help manage the resources allocated from grants, gifts and sponsored agreements. Both the University and the government have specific protocols in place to prevent the misuse of funds and other resources. Please contact your assigned contract and grant specialist if you have specific questions, or if you have questions about other forms and steps in the award process. If you are unsure of who holds the contract and grant specialist position for your department, please refer to the Administrator Directory search on the Staff Directory Page.

Direct Charging Procedure

1. SCOPE OF PROCEDURE
   This procedure outlines University of Delaware (“UD” or “University”) requirements for allocating direct costs to sponsored projects, and applies to all University departments, units, faculty, staff and students involved in externally sponsored research.
2. DEFINITIONS
   1. Direct Costs – Costs which can be identified specifically with a particular sponsored project and which can be directly assigned to such activities, relatively easily and with a high degree of accuracy.
   2. Facilities & Administrative (F&A) Costs – Costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives.
   3. Cost Principles – Fundamental conditions for ensuring costs are permissible on a sponsored project, including:
      1. Allowability or Allowable – Costs must be permissible under the terms and conditions of the award, including the authorized budget and applicable regulations
      2. Allocability or Allocable – Costs must provide a sole benefit to the sponsored project or provide proportionately assignable benefits to the sponsored project.
      3. Reasonableness or Reasonable – Both the nature of the goods or services acquired and the amount paid must reflect the action that a prudent person would have taken at the time the decision to incur the cost was made.
      4. Consistency – Application of costs must be given consistent treatment within established University policies and procedures; costs for the same purpose must be treated and classified the same way under like circumstances.
   4. Allocation – The process of assigning a cost, or a group of costs, to one or more sponsored projects and/or cost objectives.
   5. Principal Investigator (“PI”) – The individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the sponsored project (grant or contract).
   6. Sponsored Projects – Externally-funded activities in which a formal written agreement (i.e., a grant, contract, or cooperative agreement) is entered between the University and the sponsor.
3. PROCEDURE STATEMENT
   The purpose of this procedure is to ensure University compliance with applicable cost principles and federal regulations set forth for allocating direct costs per Office of Management and Budget (OMB) Circular A-21 and Uniform Guidance 2 CFR 200. Key guidance under this procedure includes:
   • Direct costs must meet conditions for allocability, allowability, reasonableness and consistency established under federal regulations.
   • A cost is allocable to a sponsored project if the goods or services involved are chargeable or assignable to that sponsored project in accordance with relative benefits received.
4. STANDARDS AND PROCEDURES
   1. Direct vs. F&A Cost Considerations
      1. Uniform Guidance establishes principles to help determine the applicability of costs to federal grants, contracts, and other agreements. It prescribes which costs are allowable for recovery from the government and, of the allowable costs, whether the educational institution should treat them as direct or facilities & administrative (F&A) costs
      2. Common examples of F&A costs include:
         1. Administrative/Clerical Staff
         2. General Office Supplies/Equipment
         3. Postage
         4. Communications (ex. Cells Phones, Telephones, Internet)
         5. Facilities Operations & Maintenance
      3. Costs that are normally considered F&A costs may be allowable as direct costs if they meet all the following criteria:
         1. An unlike circumstance exists in which a sponsored project requires resources beyond those normally expected for a typical research project;
         2. The cost can be associated with the specific sponsored project with a high degree of accuracy;
         3. The costs are not also recovered as indirect costs; and
         4. The awarding agency has explicitly approved the cost as a direct expense in the awarded budget or per written prior approval.
      4. If costs that are normally considered F&A costs are allocated as direct costs to a sponsored project, but do not meet approval criteria per section (3)(d) above, sufficient supporting justification is required to ensure the costs are allowable on the sponsored project. Otherwise, the costs will be deemed unallowable and must be removed from the sponsored project. An after-the-fact explanation attesting to the benefit to the award is insufficient justification to treat these expenses as direct costs on federal awards.
   2. Direct Cost Allocation Methodologies
      1. Direct costs may be allocated only if they advance the work of the sponsored project(s) in the same proportion as the cost.
      2. Direct cost allocations on sponsored projects should not be based on budget, funding or availability of funds, as these factors are not evidence of the allocability of a cost.
      3. Direct Cost Allocation Principles:
         1. If a cost benefits one sponsored project, it should be charged in its entirety to the sponsored project.
         2. If a cost benefits two or more sponsored projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the sponsored projects based on the proportional benefit.
         3. If a cost benefits two or more sponsored projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (d) of this section, the costs may be allocated or transferred to benefitted sponsored projects on any reasonable documented basis.
         4. Where the purchase of equipment or other capital asset is specifically authorized under a federal award, the costs are assignable to the federal award regardless of the use that may be made of the equipment or other capital asset involved when it is no longer needed for the purpose for which it was originally required.
      4. Examples of Cost Allocation Methodologies:

      GENERALLY ACCEPTABLE
      Allocation Basis	Example
      Effort	A research assistant spends 80% effort on Project A and 20% effort on Project B. The research assistant uses supplies totaling $3,000/month on the two projects. Usage is directly related to the amount of effort devoted to each project, therefore, $2,400 (80% of $3,000) is charged to Project A and $600 (20% of $3,000) is charged to Project B.
      FTEs	There are 5 FTEs employed on Project A and 8.5 FTEs employed on project B.  These are the only two sponsored projects that are performed and managed in the lab, and the monthly supplies total $5,500.  Project A should be charged $2,037.04 (5/13.5 x $5,500) and Project B should be charged $3,462.96 (8.5/13.5 x $5,500).
      Usage	The monthly cost of supplies/expendables to maintain a lab computer system is $1,000. The computer system is used solely for projects A and B. The computer operating system keeps a log of users and their time on the system. A reasonable base to allocate the expense would be computer user hours. Project A assistants have 100 combined user hours a month and project B assistants have 80 combined user hours a month. The cost allocated to project A is $560 (100 user hrs. /180 total user hrs. x $1,000). The cost allocated to project B would be $440 (80 user hrs. /180 total user’s hrs. x $1,000).
      Number of Experiments	A PI uses syringes to conduct experiments on two of his research grants. The syringes are only good for one experiment and then they must be thrown away. The PI keeps a log of how many experiments are performed on each project per week. Syringes are ordered every two weeks at $1.05 per syringe. The log indicates the following: Project A: Week 1: 25 Experiments, Week 2: 39 Experiments Project B: Week 1: 19 Experiments, Week 2: 16 Experiments The total cost of the syringes is $103.95 (99 experiments x $1.05/syringe). Project A should be charged $67.20 (64 experiments x $1.05/syringe) and Project B should be charged $36.75 (35 experiments x $1.05/syringe).
      Square Footage	A student is paid a salary of $1,500 a month to clean glassware in two laboratories that are conducting similar research. In this example, the square footage of the laboratories could be used as a reasonable basis. Lab A is 1,600 square feet and Lab B is 1,200 square feet. Lab A is charged $855 (1,600-sq. ft/2,800 sq. ft x $1,500) and Lab B charged $645 (1,200-sq. ft/2,800 sq. ft x $1,500).
      Reasonable Determination without Undue Effort or Cost	The lab has two ongoing sponsored projects and purchases a $3,000 apparatus to be used equally on both projects, so both Project A and Project B are each charged $1,500 (50%).  Since Uniform Guidance allows for proportions to be determined without undue effort or cost, the supporting justification explaining the reasonable determination is generally acceptable.
      Other Quantitative Rationale	The PI provides a quantitative rationale that is both reasonable and adequately supported with documentation, whereby the total cost can be divided based on a percentage calculated using the quantitative rationale.

      GENERALLY QUESTIONALBE OR UNACCEPTABLE
      Allocation Basis	Example
      Restocking	Restocking materials and supplies is an acceptable practice only if the usage of materials and supplies is tracked or logged and included with the supporting documentation for the transaction. If the usage is not tracked or logged, it is infeasible to adequately support that restocking transactions are allocable to the sponsored project. If the usage is not included with the supporting documentation, there is insufficient support to determine that materials and supplies benefitted the sponsored project.
      Offset	Costs were charged to Project A one month, and the next month costs were charged to Project B to offset what should have been split allocations each month between the two projects.
      Available Funding	27% of costs were allocated to Project A to zero out the remaining available balance, and the remaining 73% of costs were allocated to Project B. An exception to this would be if the entire cost was allocable to the sponsored project, but a portion of the cost was allocated to non-sponsored project funding (ex., start-up funds).
      Unreasonable Determination without Undue Effort or Cost	The lab has three ongoing sponsored projects and purchases a $3,000 apparatus to be used on each project, so Project A is charged $1,350 (45%), Project B is charged $450 (15%), and Project C is charged is charged $1,200 (40%). This is generally an unreasonable determination without additional documentation to support the specific percentages selected for the split allocation.

   3. PI/Department Responsibilities
      1. Determine the appropriate allocation methodology to use to allocate direct costs consistent with the benefits received to each sponsored program.
      2. Maintain documentation supporting allocations and review/update the methodologies as necessary.
      3. Review sponsored research projects on a regular basis (at least monthly) to ensure that all direct costs charged are correct and appropriate.
      4. Ensure that all personnel engaged in financial administration of federally-funded sponsored projects are familiar with the University direct charging procedures.
   4. Research Office Responsibilities
      1. Develop and implement direct charging procedures in accordance with the regulations outlined in Uniform Guidance 2 CFR 200, Subpart E – Cost Principles.
      2. Assist in the interpretation and implementation of the direct charging procedures.
      3. Periodically review justifications and/or supporting documentation provided for direct cost allocations to sponsored programs to ensure documented adherence to the direct charging procedures.

Draft Master Research Agreement with Industry

The Draft Master Research Agreement with Industry is a template of a contract between UD and the sponsor; it specifies the obligations of UD and the sponsor in funding and conducting any scope of work that UD may propose for funding by that sponsor.

Effort Reporting Template

This form is used to help manage the resources allocated from grants, gifts and sponsored agreements. Both the University and the government have specific protocols in place to prevent the misuse of funds and other resources. Please contact your assigned contract and grant specialist if you have specific questions, or if you have questions about other forms and steps in the award process. If you are unsure of who holds the contract and grant specialist position for your department, please refer to the Administrator Directory search on the Staff Directory Page.

Equipment Inventory Template

This template is used to report equipment inventory to the sponsor. Please contact your assigned Sponsored Research Accountant with any questions regarding this form.

Equipment Screening Policy

1. POLICY
   All proposed purchases of equipment using federal or federal flow-thru funds having a requisition cost of $5,000 or more are subject to the screening program to determine if like equipment exists on campus and is available for use.
2. SCOPE OF PURPOSE
   To meet Federal government requirements for the purchase of equipment funded in sponsored programs.

The authority to enforce this policy lies within the Procurement Services Department. Any questions may be directed to (302) 831- 2161 or procurement@udel.edu.

The complete policy and more can be found on the General Counsel’s web site.

External Sponsorship and Grant

1. POLICY
   It is important that the long-range implications of the acceptance by the University of any external grant be carefully considered. In the past, the University has sometimes found itself in a position where the acceptance of these grants has resulted in serious budgetary commitments which extended far above and beyond the grant income. This has been particularly true in the case of federal, departmental, or program developmental grants which have involved continuing financial commitments for staff, equipment, and other items.
2. SCOPE OF PURPOSE
   To insure that acceptance of external grants by faculty members does not create unforeseen and unrealized financial burdens for the University.

ALL proposals and awards with the exception of those that fall within the limits of delegated authority must be approved and signed by the Vice Provost for Research or his or her designee.

The complete policy and more can be found on the General Counsel’s web site.

Fly America Act and Open Skies Agreements

Generally, if a traveler is traveling on funds provided by the federal government, he/she must* use a U.S. flag carrier (an airline owned by an American company), regardless of cost or convenience.

If you are scheduling international travel that is federally funded, you must ensure that all flights, where possible, are scheduled on U.S. flag carriers or on foreign air carriers that code share with a U.S. flag carrier. Code sharing occurs when two or more airlines “code” the same flight as if it was their own. In other words, a U.S. airline may sell a seat on the plane of a foreign air carrier; this seat is considered the same as one on a plane operated by a U.S. flag carrier. Compliance with the Fly America Act is satisfied when the U.S. flag air carrier’s designator code is present in the area next to the flight numbers on the airline ticket, boarding pass, or on the documentation for an electronic ticket (passenger receipt).

Related Links

FAQ’s

Fly America Waiver Checklist

Fly America Waiver Checklist

This checklist assists in determining qualification for a waiver of the restrictions of the Fly America Act under 41 CFR Part 301-10.

Fringe Benefit Rate Agreement

UD FY24 Fringe Benefit Rate Agreement

INSTITUTION: UNIVERSITY OF DELAWARE, NEWARK, DE 19716-0099

The Fringe Benefits rates contained herein are for use on grants, contracts and/or other agreements issued or awarded to the University of Delaware by all Federal Agencies of the United States of America, in accordance with the cost principles mandated by 2 CFR Pa11 200. These rates shall be used for forward pricing and billing purposes for the University of Delaware Fiscal Year 2024. This rate agreement supersedes all previous rate agreements/determinations for Fiscal Year 2024.

SECTION I: RATES – TYPE: FIXED

Fringe Benefits Rates:

*Excludes student wages exempt from FICA.

Related Links

UD-FY-2024 Colleges and Universities Rate Agreement

Gifts or Sponsored Agreements Checklist

This document is meant to provide guidance to determine if a transaction is a gift to be processed and administered by the Office of Development & Alumni Relations (DAR) or the Research Office (RO). See UD Gift Policy Section 8 (Gift vs. Sponsored Project) for complete details about how to make this determination.

Download the form below and answer all eight questions in the checklist, including comments whenever necessary. To use this form, review all the documentation associated with the funding for indications that will help you to determine whether the funding should be considered support for a sponsored project or a gift.