Financial Management

Administrative or clerical staff must be integral to a project in order to be direct charged to a federal award and must be budgeted and justified in the proposal or have prior written sponsor approval. Under the Uniform Guidance (section 200.413), a project no longer needs to be identified as “major” to include administrative salary, but in general such expenses should be treated as indirect (F&A) costs.

To be integral to the project, the administrative activity should be:

• essential or vital to the project, and described accordingly in the justification;
• budgeted at a percentage of a person-month that reflects that essential nature (a minimum of 10% FTE);
• performed by individuals specifically identified with the project or activity; and
• costs that are not also recovered as indirect costs.
• For non-federally sponsored projects, administrative or clerical staff may be direct charged provided they benefit the project and follow those sponsors’ requirements for the award.

Since these items are explicitly identified in the proposal, the assumption is the sponsoring agency approves this treatment of administrative and clerical salaries or other costs if they accept the proposal and subsequently fund the project. If the proposal and award document has not specifically identified these costs, the University is not allowed to rebudget approved funding to these categories unless specific written approval has been received from the sponsoring agency or delegated under expanded authorities for rebudgeting.

Treatment of administrative costs as direct costs must be uniform across projects. Administrative costs may be budgeted as direct costs only if this type of cost is consistently treated as a direct cost in like circumstances for all other projects and cost objectives.

Examples of circumstances where administrative or clerical costs may be considered essential include:

1. Large, complex programs such as Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.

2. Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting.

3. Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.

 4. Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).

5. Projects geographically inaccessible to normal BSC administrative services.

6. Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.

These examples are not exhaustive, nor are they intended to imply that direct charging of administrative or clerical costs would be appropriate under similar circumstances.

SPA staff are available to assist in the interpretation and application of University policy and Uniform Guidance.

Whenever possible, specific expenses should be individually charged to a specific sponsored award.  When it is not possible or efficient to determine how much of the cost is used for each award, allocation of the expenses is allowable.  Allocation is the process of assigning a cost to one or more awards in reasonable and realistic proportion to the benefit provided to the individual projects.

Cost Allocation Methodology Guidance

Cost sharing is that portion of "allowable" externally sponsored program costs not borne by the sponsor. "Matching" is a form of cost sharing often characterized by a required ratio (e.g., 1:1) of cost sharing to sponsor supported costs. The distinction between cost sharing and matching is not as important as the management and accounting for these project costs. When cost sharing or matching is provided through expenditure of other funding sources by the University the supporting documentation is based on cash outlays and recorded in project funds (15C funds). When the cost sharing or matching is provided through third party expenditures on behalf of the project, the substantiation of the value of the cost sharing or matching must be accepted by the University. In-kind cost sharing or matching contributions are donated services, use of non-University equipment, or space, that do not require any cash outlay therefore require special care in substantiating the values. These in-kind contributions are recorded in 16C accounts.  Cash contributions from external sources are recorded in 17C accounts.  The most important source of information on nonfederal cost shares can be found in Uniform Guidance.

UNIFORM GUIDANCE

POLICY

PROCEDURES

Cost transfers between grants and funds are a common and acceptable accounting practice in research universities and also subject to federal audit scrutiny. Timely cost transfers to correct accounting errors and distribute costs are generally appropriate. Cost transfers not completed within 90 days of the original transaction date recording the expense require central office (SPA, Cooperative Extension, or Ag Experimentation Station) approvals as federal sponsors have determined that cost transfers completed more than 90 days after the original expense transaction are a risk of an unallowable cost. Transfers from one project to another or from one competitive segment to another solely to cover cost overruns are not allowable.

University’s policy on cost transfers

Cost Transfer Justification Form

Cost Transfer Frequently Asked Questions

Definition:

A Course Buyout, sometimes referred to an instructional release is when grant funds “buy” a faculty member’s released time by paying for that portion of their salary so that the equivalent amount of effort can be spent working on the grant.

Guidelines:

In order to receive a course buy-out, the researcher must obtain documentation of approval from the Department Chair before proposal submission.  Once approval is received, SPA will budget 12.5% effort plus fringe benefits, during the 9-month academic calendar.

Management of course buyout funds

In the event of a successful proposal, in which a course buyout has been budgeted and approved, the faculty member’s labor for the semester of the buyout should be modified to charge the budgeted salary to the fund number established for the new award.

This will result in a surplus in the unit’s salary account and can be used to pay the replacement instructor and any other expenses at the discretion of the College, such as costs of visiting or adjunct faculty or enhancing operational support of faculty development and student learning.

In the case of buyouts being paid from PI Help accounts, an amount equal to 12.5% of the faculty member’s salary, will be transferred from the PI overhead account into a unit designated account.  These funds will then be used to pay the replacement instructor and any other expenses at the unit’s discretion as described above.

Example of course buyout calculation:

Professor John Doe has a nine-month academic salary of $90,000. Professor Doe received a grant in which a course buyout was budgeted and awarded for the Spring semester for $11,250 (1/8 of $90,000).

For the spring semester, Professor Doe’s labor distribution should be changed:

From:

100% charged to college/department salary account, i.e., $90,000

To:

      1.3/4 charged to university salary account $78,750

     2. 1/4 charged to new grant award $11,250 for the spring semester

This will correctly charge the grant $11,250 for the spring semester and leave a balance of $11,250 in the university salary account which will be made available to the College/Department to be used to pay the replacement instructor and other expenses at the discretion of the College.

Please work with your STAR GCA to ensure that your labor is properly distributed during the semester of the course buyout.

Upon acceptance of a federal award, the university becomes responsible and accountable for the Government property acquired with the underlying grant funds.  The federal Government's guidance, rules and regulations codified in Uniform Guidance require the University to procure, use, and control property in accordance with Federal laws, executive orders, and directives from granting Sponsoring Agencies.  The Government relies upon the University's internal control structure, environment and procedures to ensure compliance and adherence with these requirements.

Definitions of terms associated with government property:

Contractor - includes any person or organization that enters into a contract with the United States or any department or agency thereof.  For purposes of this guidance, UNH is the contractor.

Contracting Officer - Government representative who enters into, administers, or terminates contracts on behalf of the Sponsoring agency.

Government property:

• Government-furnished property - property in the possession of, or directly acquired by the Government and subsequently furnished to the Contractor for performance of a grant or contract.
• Contractor-acquired property - property acquired, fabricated or otherwise procured by the Contractor performing a contract, to which the Government has title.

Property Administrator - an authorized representative of the Contracting Officer assigned to administer the contract requirements and obligations relating to government property in the custody or control of the Contractor.

Pre-Acquisition Screening

A required process when equipment is being purchased with federal funds to determine the existence of similar assets on campus prior to acquisition of assets required by or specified in a grant to avoid duplicating asset purchases.  Screening must occur even when the equipment require is specifically approved and funded in the award.  Certain federal agencies may require additional screening which would be specified in individual award documents, if required.

Records

The university's Fixed Asset Management Office (FAMO) is responsible for maintaining the Fixed Asset System in Banner Finance.  This system contains the official property records of the university in the form and structure required or mandated by Sponsoring Agencies.  The property records include information such as location, description, unit acquisition cost, asset type and tag date for each individual piece of equipment acquired which meets the University capitalization threshold.

Physical Inventory

As required by Uniform Guidance, the university conducts a physical inventory on a biennial basis and the results are reconciled with current property records.  All equipment encompassed by this section is subject to the biennial inventory.

Subcontractor Control of Government Equipment

For subcontracts involving equipment, UNH delegates to the subcontractor, via the subcontract document, responsibility for all government equipment acquired or borrowed by a subcontractor.  Each subcontract entered into must contain specific provisions concerning the subcontractor's responsibility for government property.  Such provisions require that the subcontractor assume the same responsibility and obligations of UNH (those outlined within this policy) with respect to the property while it is under the subcontractor's control.  The subcontractor's property control system should include procedures necessary for satisfying these requirements and responsibilities.

Reporting of Government Property in the Possession of the University

The FMAO is responsible for preparing annual, special or periodic property reports required by federal agreements.  The applicable university Department, its Dean or their designee, and the PI are responsible for investigating any loss, damage, destruction or theft of equipment and must promptly furnish a written narrative to the FMAO as soon as the facts become known.

Utilization of Equipment

The PI, their designee, or the responsible university employee should restrict the utilization of equipment acquired for use under a specific grant or contract to the purposes of that grant or contract unless otherwise noted in the award document or written approvals from the Contracting Officer.

Periodically, all property including government property in the custody of a department should be reviewed for utilization.  Any property that is either temporarily or permanently not in use should be reported as excess equipment to the FMAO.   .

Equipment Care and Maintenance

Principal Investigators, their designees and departments are responsible for safeguarding government property against loss or damage. PIs and other responsible individuals must ensure that the property is maintained and repaired by qualified personnel or return it to the manufacturer when repairs are required.

Sponsored Program Related Property Closeout 

Immediately upon termination or completion of a government grant or contract, the department, PI or individual(s) having custody of equipment must perform a physical inventory adequate for appropriate disposition of all government property. The PI or their designee should work with Sponsored Programs Administration and the FAMO to request disposition instructions from the agency.

The university is relieved of responsibility for government owned property only when the:

• Sponsoring Agency Property Administrators determine when property has been consumed or expended properly and in reasonable amounts in the performance of the federal contract.
• Government property is shipped from UNH pursuant to the Property Administrator instructions.
• Title transfers to UNH and thereby ceases to be government property pursuant to the grant or contract provisions.

Questions regarding this guidance should be directed to the Fixed Asset Management Office.

Click to view the policy on Equipment.

The Principal Investigator (PI) has overall responsibility for the technical and fiscal management of a sponsored project. This includes ensuring that project activities are conducted within approved funding limitations, expenditures are consistent with the project's scope of work, reporting requirements are met, and the sponsor is notified when significant changes in project status or performance require sponsor approval or notification.

The University maintains a comprehensive system of internal controls designed to ensure that sponsored project expenditures are reasonable, allowable, allocable, consistently treated, and properly documented. Financial stewardship is a shared responsibility among the PI, Sponsored Programs Administration (SPA), and for some units, business administrators. Through Workday business processes, project expenditures are reviewed and approved at multiple points, including requisition approvals, expense approvals, payroll processing, effort certification, and periodic reviews of cost allocations.

As part of this system of internal controls, PIs are expected to regularly monitor the financial status of their sponsored projects and review project expenditures to ensure they accurately reflect the work being performed. While many financial controls occur as part of Workday workflows, ongoing oversight by the PI remains essential throughout the life of the award.

SPA partners with Principal Investigators by conducting quarterly project review meetings to discuss project expenditures, budget status, burn rate, projected spending, compliance requirements, upcoming deadlines, and any issues requiring corrective action. Cost allocations are reviewed at least quarterly to ensure expenses are appropriately distributed among benefiting projects and supported by a reasonable and documented allocation methodology. Salary charged to sponsored projects is further confirmed through the University's annual effort certification process.

Supporting documentation for all sponsored project expenditures must be maintained in accordance with sponsor requirements, applicable federal regulations, and University record retention policies. Documentation must be sufficient to demonstrate that expenditures are reasonable, allowable, allocable, and directly benefit the sponsored project. If adequate documentation cannot be provided, a sponsor may disallow the expenditure, and the cost must be transferred to an appropriate non-sponsored funding source.

Regardless of the approval workflow, PIs should periodically confirm that expenditures charged to their projects:

• Directly benefit the sponsored project. 
• Are reasonable, allowable, and allocable. 
• Are charged to the correct project and budget category. 
• Are accurately recorded and appropriately documented. 
• Comply with the terms and conditions of the award, sponsor requirements, applicable federal regulations, and University policy.

Key internal controls include:

• Requisition and Expense Approvals – Purchases charged to sponsored projects are reviewed and approved by the PI or SPA, as appropriate, through the University's Workday workflow to ensure expenditures are consistent with the project scope, budget, sponsor requirements, and University policy. 
• Payroll and Time Reporting – Time worked by hourly employees is recorded and approved through the University's Workday Time Tracking system. Salary charges for salaried employees are supported through institutional payroll processes and are confirmed through the University's annual effort certification process. 
• Cost Allocation Reviews – Cost allocations are reviewed on at least a quarterly basis to ensure expenditures are appropriately distributed among benefiting projects and supported by a reasonable and documented allocation methodology. 
• Quarterly Project Review – SPA meets with Principal Investigators on a quarterly basis to review the financial status of sponsored projects, including expenditures, burn rate, budget balances, encumbrances, projected spending, and any compliance or administrative issues requiring attention. 
• Principal Investigator Oversight – Throughout the life of the award, the PI is responsible for reviewing project expenditures and ensuring that costs charged to the project are appropriate, directly benefit the sponsored activity, and comply with the award terms and conditions. 

The University's integrated review and approval processes provide reasonable assurance that expenditures charged to sponsored projects comply with sponsor requirements, applicable federal regulations, and University policy. Supporting documentation must be maintained in accordance with sponsor requirements, applicable federal regulations, and University record retention policies.

Pre-Approval Requirement

USNH Travel Policy

Sponsor regulations regarding foreign travel vary. For this reason, all federally sponsored international travel must be pre-approved by the campus Sponsored Programs office.  Requests for pre-approval should include the traveler's name, destination, cost, airline carrier (federal awards require U. S. flag carriers or carriers with an exception to the Fly America Act described below), source of funds, purpose of the travel, and ticket classification (e.g., the coach, business, first class, etc.). This information should be included when the traveler is requesting pre-approval.

The Fly America Act

Fly America Act

The Fly America Act mandates the use of U.S. flag carriers when traveling on funds provided by the federal government unless permitted exceptions exist. U.S. flag carriers are airlines owned by an American company. The choice to “Fly America” is made regardless of cost or convenience. Travel with a foreign air carrier must be necessary and meet the exception criteria defined by the Fly America Act.

Fly America Act Exceptions

Fly America Act Exception Form

The biggest exception to the Fly America Act is the Open Skies Agreement. On October 6, 2010 the Unites States and European Union (EU) “Open Skies” Air Transport Agreement was published by the U.S. General Services Administration (GSA) providing full explanation of the multilateral agreement in place so that qualifying travelers, whose travel is supported by federal funds, may travel on European Union (EU) airlines as well as U.S. flag air carriers. There are also Open Skies agreements with Australia, Switzerland, and Japan. When traveling to a destination serviced by a European Union airline, USNH travelers flying on a federal grant can fly on either a US carrier or an EU carrier as long as they touch down in an EU Country.

i.    USNH travelers on federal Funds cannot use city-pair¹ contracts
ii.   USNH travelers flying on a federal grant can use an Australian airline if the origin/destination is either the US or Australia and no city-pair contract flight between the two points (origin and destination) exists.
iii.  USNH travelers flying on a federal grant can us a Swiss airline if a point of origin/destination is either the US or Switzerland and no city-pair contract flight between the two points (origin and destination) exists.
iv.  USNH travelers flying on a federal grant can us a Japanese airline if a point of origin/destination is either the US or Japan and no city-pair contract flight between the two points (origin and destination) exists.
v.   Travelers using funding from U.S. Department of Defense (DOD) or Secretary of a military department such as the Air Force, Army or Navy, are not permitted to take advantage of the open sky agreements. Travelers using these funds must use a U.S. flag carrier, unless they qualify for a permitted exception of the Fly America Act. If you are unsure if an exception exists, contact the responsible accounting and financial compliance representative for the award.

Caution: The costs of travel subject to the Fly America Act that do not adhere to this federal regulation will be borne by the Principal Investigator’s department or will need to be transferred to a suitable non-federal funding source.

This guidance is provided for the payment of incentives to human subjects participating in research projects, and to determine when the gathering of research participant tax information is required.

HUMAN SUBJECT INCENTIVE PAYMENTS

Labor Distribution and Salary Cost Management

The largest category of direct sponsored program expenses is salary and benefits. The principal investigator (PI) is responsible for reviewing salaries charged to projects, and for validating and certifying percentages of salary charged to a project.

Salary Distribution and Certification

When a principal investigator (PI) manages a laboratory with multiple ongoing projects, the allocation of salary charges for the PI, research assistants, researchers, and other personnel must accurately reflect the work performed on each project. The University of New Hampshire's salary distribution and effort certification process ensures that direct labor charges to federally sponsored agreements are reasonable, properly allocated, and supported by actual effort. Commonly referred to as effort certification, this process documents the distribution of an individual's effort across all institutional activities as a percentage of total institutional effort—not as a specified number of hours. Effort may be charged directly to a sponsored project or contributed as committed cost sharing.

Charges for work performed on sponsored agreements during the academic year are based on an individual's regular compensation for the continuous period that constitutes the basis of his or her salary. For purposes of this guidance, salaries and wages include compensation for vacation, holidays, sick leave, and other paid absences as part of the normal cost of salaries and wages. Separate claims are made only for short-term disability through the application of the University's fringe benefit rate. Accordingly, the first five days of a short-term disability absence are charged as sick leave and treated as part of the normal cost of salaries and wages.

Salary charges to sponsored projects are allowable only at the individual's Institutional Base Salary (IBS) rate. Under no circumstances may charges to a sponsored agreement exceed the proportionate share of the individual's IBS applicable to the period of performance, regardless of the method used to calculate the salary charge. See the Institutional Base Salary (IBS) guidance for additional information. Some sponsors impose salary caps that limit the amount of salary that may be charged to an award. Any salary in excess of an applicable sponsor-imposed cap is unallowable and must be funded from non-sponsored sources.

Salary charges for faculty members performing work on sponsored agreements during the summer months are calculated separately. Summer salary may not exceed the faculty member's Institutional Base Salary divided by the number of months in the academic-year appointment. For example, a faculty member with a nine-month appointment who devotes one month of effort during the summer may charge no more than one-ninth of the academic-year base salary to the sponsored project. See the Summer and Supplemental Pay guidance for additional information.

PIs are responsible for ensuring that salary charges remain consistent with the actual level of effort devoted to a sponsored project. If a PI or other key personnel identified in the award will devote less effort than originally proposed, the PI and the responsible department should:

• Determine whether sponsor notification or prior approval is required.
• Review and adjust salary charges, as appropriate.
• Review and revise any salary-based cost-sharing commitments, if applicable.

For federally sponsored awards, prior written approval from the sponsor is generally required when the PI or other key personnel named in the award will reduce their committed effort by 25 percent or more from the approved level. For example, if an award includes one month of committed PI effort but the PI anticipates devoting only one-half month, the PI must request sponsor approval before reducing the effort commitment. The request should explain the reason for the reduction and describe how the project objectives will continue to be met. All such requests must be coordinated through the assigned Pre-Award Compliance (PAC) Grant and Contract Administrator (GCA), who will submit the request to the sponsoring agency on the University's behalf.

This version reduces repetition, groups related concepts together (effort certification, salary allowability, summer salary, and effort reductions), and uses language consistent with federal regulations and university research administration guidance.

This guidance is provided for meals charged to sponsored projects and for determining reasonableness, allocability and allowability of costs.

MEALS ON FEDERALLY (OR FEDERAL FLOW-DOWN) SPONSORED PROJECTS

This guidance is to define participant support costs and to provide information regarding this budget element. 

PARTICIPANT SUPPORT COSTS ON FEDERAL FUNDED PROJECTS

At Time of Proposal

1. The Principal Investigator (PI)/Project Director (PD) who anticipates that program income will occur during an externally sponsored project includes in the initial and/or continuation proposal an estimate of the amounts (non-binding) and sources of the anticipated income. The amounts are entered on the appropriate lines of the sponsor-specific form, if a form is required, and/or explained in detail in the proposal budget narrative.
2. Unless there is required cost sharing for the project and that cost sharing will need to be met with program income, the PI/PD requests in the proposal that the “additive method” be approved by the sponsor. The justification for this method is detailed in the proposal budget narrative. (One needs to consider the possibility that the “deductive method” may be applied at the sponsor’s discretion.)
3. When budgeting for the proposed program or project, the PI/PD includes in the anticipated program income expenses the applicable fringe benefits and Facilities and Administrative (F&A) costs. The office of Sponsored Program Administration confirms that fringe benefits and F&A line items are included in the proposal budget prior to submission to the sponsor.

At Time of Award and Post-Award

1. During the negotiation process for a new award and for unanticipated program income realized during the project period, the office of Sponsored Program Administration works with the sponsor and the PI/PD to clarify the applicable program income application method.
2. The office of Sponsored Program Administration establishes a unique program income account within the appropriate series (15P…) in the USNH financial accounting system and links the program income account to the specific externally sponsored program account that it supports. (In Banner Finance, the program income fund has the same grant number as the related award.) No budget is established until actual program income is received by the PI/PD’s Responsibility Center (RC) unit.
3. When actual program income is received, the RC unit deposits the revenue in the appropriate program income account established by the office of Sponsored Program Administration, and provides the office of Sponsored Program Administration Grant and Contract Administrator (GCA) with a copy of the check or evidence of cash receipt or bank transfer, the program income account number, and the requested budget line items. The office of Sponsored Program Administration will establish and/or modify the budget, with sufficient funds to cover anticipated direct and associated fringe benefits and F&A costs. It is the responsibility of the office of Sponsored Program Administration to ensure the appropriateness of re-budgeting program income accounts.
4. It is the responsibility of the RC unit to monitor program income account revenues and expenses, just as for the parent account in order to ensure that expenditures are allowable under sponsor and UNH policies and to avoid deficit spending. If there is a program income account deficit or balance at the end of the project period, office of Sponsored Program Administration works with the PI/PD, and RC unit financial manager, to determine how to best remove the account deficit or deal with the balance under the terms of the sponsored programs award. The office of Sponsored Program Administration Financial Research Administrator (FRA) will close program income accounts in the USNH financial accounting system after the end of the project period and all reconciliations have been done.
5. As specified in 2 CFR 200 §200.307(f) “there is no Federal requirements governing the disposition of income earned after the end of the period of performance for the Federal award, unless the Federal awarding agency regulations or terms and conditions of the Federal award provide otherwise.”  This clause will also be applied to program income generated after a non-Federal award expires, unless the terms and conditions of the award specify otherwise.

SPA will advise the RC Unit/PI on the appropriate method of accounting for the program income earned after the award has expired.

Uniform Guidance defines program income as "gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the award."

UNIFORM GUIDANCE

Program income includes:

• Fees earned from services performed under the project, such as laboratory tests;
• Funds generated from sales of commodities and research materials, such as tissue cultures, cell lines and research animals;
• Conference fees charged when a grant funds a conference;
• Income from registration fees, consulting, and sales of educational materials; and
• Sale, rental, or usage fees, such as fees charged for the use of computing or laboratory equipment purchased with grant funds

University policy on program income is available in the On-line Policy Manual.

This guidance is provided for faculty who choose to devote effort and receive compensation from sponsored projects during the summer or as supplemental pay.

SUMMER AND SUPPLEMENTAL PAY

Sponsored Programs Summer Compensation Request

Definitions

Visa costs are defined and described as allowable in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.463(d) as:

Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a federal award.

Visa costs discussed in this policy are specifically associated with research-related visas. See International Student and Scholars for additional information on visas. 

Federal Awards

Under the guidelines imposed by the Uniform Guidance, visa costs may be considered allowable direct charges under certain circumstances, and Principal Investigators (PIs) need to demonstrate that such costs fit the criteria provided in the Uniform Guidance. Visa costs are allowable, provided that they meet all four of the following conditions:

• Be critical and necessary for the conduct of the project, and
• Be allowable under the applicable cost principles, and
• Be consistent with the university's cost accounting practices and procedural statement regarding sensitive expenses, and
• Meet the definition of “direct cost” as described in the applicable cost principles (2 CFR 200.413(a) and (b)).

The Uniform Guidance categorizes visa costs as a recruitment cost (2 CFR 200.463). Therefore, in like circumstances, visa costs are limited to initial costs only.

The following visa types may be allowable as a direct charge:

• H-1B petition expenses. An H-1B visa is a non-immigrant visa that allows US companies to employ foreign workers in specialty occupations that require theoretical or technical expertise in specialized areas. If the individual is being recruited to work on the sponsored project, H-1B visa fees are chargeable to that sponsored project because that project will receive a direct benefit from the university’s appointment.
• O-1 Visas. An O-1 visa is a non-immigrant visa for an individual who possesses extraordinary ability in the sciences, arts, and education. O-1 Visas may be charged to sponsored projects if there is a clear and direct benefit derived by the sponsored project to justify charging the expenses.
• J-1 Visas. A J-1 visa is a non-immigrant visa issued to research scholars, professors, and exchange visitors participating in programs that promote cultural exchange. J-1 Visas are allowable when the purpose of the visiting scholar or faculty exchange is to work on one or more sponsored projects.

The following costs related to visas are unallowable:

• All student (F-1) visas. The primary purpose of an F-1 visa holder is to join the university community as a student, and participation on sponsored projects is incidental to their roles as students.
• J-1 visas. The policy generally excludes exchange visas for visiting scholars or professors to come to the US to participate in teaching, scholarship, or research, unless the purpose is specifically to participate in a sponsored project. (See J-1 Visas above)
• All Permanent Residency requests. The primary beneficiary for a Permanent Residency request is the individual, and direct benefits to individual research projects cannot readily be shown.
• If the newly hired employee resigns within 12 months after hire for reasons within his or her control, all associated relocation costs, including any visa costs, must be removed from the federal award and charged to a departmental account. If the unit terminates the employee, the costs are still allowable.
• Fees for expedited processing, cannot be direct charged to a sponsored project.
• Renewal fees for visas cannot be direct charged to a sponsored project as they are not part of the initial recruitment cost.

B. Non-Federal Awards

Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. The basic criteria for including visa costs are similar for non-federal sponsored projects, but it is important to be familiar with the particular requirements or restrictions of each non-federal sponsor. When allowed by the sponsor, a justification for the inclusion of visa costs should be provided in order to explain why they are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project.