Sponsored Programs

Mission Statement: To serve and assist faculty toward their goal of outstanding research and scholarly activities and provide stewardship of sponsored funds through responsible management of contracted activity.

Effort Policy for Proposals

• Actual effort expended on each project must be certified by a responsible person with suitable means of verification that the work was performed, generally the principal investigator (PI), at the end of specified reporting periods. The effort certification should be a reasonable estimate of how time was expended.
• Generally, faculty cannot commit 100% of their effort on sponsored projects, as time must be reserved for other CSU duties. For Administrative Professionals and State Classified staff, up to 100% of effort may be devoted to sponsored projects. However, allocations of effort to sponsored projects must be reasonable given the individual’s non-sponsored University activities.
• Effort must be certified for all individuals who receive salary support from a sponsored project and those who expend committed effort on a sponsored project without receiving salary support from the sponsor. Principal Investigators certify the effort of all staff on each project. Project effort reports must be certified in a timely manner.The effort devoted to a sponsored project should be consistent with the plan that was proposed to the sponsoring agency and agreed to at the time of the award. All Key Personnel must devote at least a one percent commitment to that project, with a few exceptions such as equipment grants, and dissertation grants.All principal investigators, faculty, and staff who are involved in proposing, executing, directing, or managing sponsored projects are responsible for:
  • understanding the fundamentals of effort and commitment management and effort certification
  • proposing, expending, and managing effort in accordance with the award and all applicable sponsor policies and University procedures
  • completing any required educational programs associated with effort reporting

  The policy of Warner College of Natural Resources regarding PI/key personnel effort on proposals is as follows;

  All proposals must have demonstrated, and charged, effort by all key personnel, unless explicitly prohibited by the solicitation/guidelines.  CSU has defined demonstrated effort as 1% effort annually. Key personnel is an individual who contributes to the scientific development or execution of the project in a substantive, measurable way. The full policy can be found at http://policylibrary.colostate.edu/policy.aspx?id=756

  The College encourages PIs and key personnel to search for other ways to cut costs in budgets rather than not including some effort for key personnel.

  The practice of not including key personnel effort in proposals submitted for external funding creates Voluntary Uncommitted Cost Sharing which CSU is required to compute into their organized research base which has an overall negative impact on the University negotiation of our indirect cost rates.

  The Uniform Guidance issued by the Office of Management and Budgets includes a reference to Memoranda 01-06 Clarification of OMB A-21 Treatment of Voluntary Uncommitted cost Sharing.  This memoranda includes the following information;

  Most Federally-funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the Federal Government. This effort can be provided at any time within the fiscal year (summer months, academic year, or both). Such committed faculty effort shall not be excluded from the organized research base by declaring it to be voluntary uncommitted cost sharing. If a research program research sponsored agreement shows no faculty (or senior researchers) effort, paid or unpaid by the Federal Government, an estimated amount must be computed by the university and included in the organized research base. However, some types of research programs, such as programs for equipment and instrumentation, doctoral dissertations, and student augmentation, do not require committed faculty effort, paid or unpaid by the Federal Government, and consequently would not be subject to such an adjustment.

  Criteria for Direct Charging of Normally Indirect Costs

  Administrative/Clerical Salaries

  Uniform Guidance (http://uprnet.research.colostate.edu/OSP/uniform-guidance) provides that while administrative and clerical staff should normally be treated as indirect costs, direct charging of these costs may be appropriate where the nature of the work performed under a particular project:

  • Is required by the scientific aims of the project;
  • Is above what would normally be expected from departmental support staff, or
  • Is required by the specific terms of an award provided the need is justified and the cost is explicitly budgeted in the award document.

  Administrative/clerical activities which meet these criteria include:

  • Extensive data accumulation, analysis and entry, surveying, tabulation, cataloguing, searching literature, and reporting
  • Travel and meeting arrangements for large numbers of participants, e.g., conferences/workshops/seminars;
  • Complex travel arrangements, e.g., international travel, travel to multiple locations, etc.;
  • Copying of reports and/or articles needed for conduct of research (vs. copying technical information for general use)
  • Multiple project-related investigator coordination and communications
  • Preparation of manuals and large reports, books and monographs
  • Technical typing, e.g., reports with equations, graphs, tables, etc.
  • Maintaining project-specific databases
  • Preparation of materials for mailing to the sponsor on an on-going basis
  • Activity at an off-campus site

  Administrative/clerical activities, which do not meet these criteria include:

  • Routine progress and technical reports
  • Routine correspondence with the sponsor Routine travel arrangements
  • Routine financial transaction processing
  • Routine scheduling of meetings
  • Routine travel arrangements
  • Routine financial transaction processing
  • Routine scheduling of meetings

  Departmental Administration Expenses

  Uniform Guidance stipulates that in developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or indirect costs.  Departmental administration costs specifically identified as normally indirect are administrative/clerical salaries, office supplies, postage, local telephone service, and memberships.

  The Federal Government has established some criteria for determining when it may be appropriate to charge normally indirect costs as direct costs on Federal awards.  A different purpose would be directly related to the technical objective of the award; a different circumstance would be an effort greater than the routine level of services provided by the academic department.  Accordingly, we must distinguish between costs we incur only for the accomplishment of specific project objectives and those incidentals to our overall institutional activities.  Charges must be:

  • Based on established policy, consistently applied
  • Based on legitimate differences in purpose and circumstances
  • Specifically identified with the project, and can be measured
  • Actual costs (vs. just charging the budgeted amounts)
  • Justified to the satisfaction of the sponsor in the proposal and specifically funded in the award

  Proposals requesting direct funding for those costs normally treated as indirect costs must contain a complete justification based on the criteria established below.  In the event that a sponsor rejects such justification, either in whole or in part, such costs not approved by the sponsor must be charged to a departmental administration account.

  If during the performance of a project the principal investigator identifies a need to direct charge any of the departmental administration costs normally treated as indirect, this may be accomplished by submission of an institutional prior approval form, provided all of the following conditions are met:

  • The sponsor’s written policy provides for such a budget redistribution;
  • The purpose and circumstances meet the criteria established below and are adequately justified on the prior approval form; and
  • There are sufficient funds available for the charges.

  Office Supplies vs. Project Supplies

  Office supplies are those supplies normally maintained in a departmental stock for general use by all staff.  Costs for such supplies will be treated as indirect and charged to a departmental administration account.  Such items would include:

  • Pens and pencils
  • Paperclips
  • Writing tablets and pads
  • Departmental letterhead and envelopes
  • Non-consumable supplies, e.g., staplers, wall clocks, wastebaskets, etc.

  Project supplies are those supplies not normally maintained in a departmental stock for general use but needed for specific project needs.  Costs for such supplies will be allocated to benefiting projects.  Such items would include:

  • Project letterhead and envelopes
  • Unusually large quantities of certain supplies, e.g., computer disks, disk files, file folders, No.2 pencils for surveys, etc.
  • Supplies for laboratory or special facility dedicated to project use, e.g., lab books, file folders, binders, etc.
  • Supplies needed at an off-campus site where a departmental stock is not available

  Basic Telephone Service

  The cost of providing telephone lines for departmental staff is normally treated as indirect and will be charged to a departmental administration account.  Project specific needs which would justify direct charging of telephone service would include:

  • Need for dedicated line for computer link, for conducting surveys, etc.
  • Need for phone service in a laboratory or special facility dedicated to project use
  • Need for phones for staff added specifically for project duties
  • Need for phone service at off-campus site

  Postage

  Routine postage costs are normally treated as indirect and will be charged to a departmental administration account.  Project-specific needs, which would justify direct charging of postage costs, would include:

  • Proposal costs incurred pursuant to a specific requirement in a contract (e.g., re-pricing options, or pricing un-priced options) versus preparing proposals which do not result from such a specific requirement i.e., for the benefit of the overall unit
  • Special financial reporting requirements unique to an award, i.e., more detailed than the FRS information reported by Sponsored Programs accounting staff
  • Preparation of project-specific regulatory protocol
  • Special insurance

  CAS 501: Consistency in Estimating, Accumulating and Reporting costs

  The purpose of CAS 501 was created to enhance the ability to compare budgeted costs with actual costs.  This standard requires the University to conduct federally sponsored projects in the manner that was identified in the proposal.  It will require greater accuracy in developing proposal budgets.  Cost classifications used to estimate costs in grant and contract proposals must be consistent with the classifications used to accumulate and report costs to permit comparisons of the estimates to actual costs.  CAS 501 requires accurate cost accounting—assigning full costs to the activities they support.  While the cost accounting standards are directed at Federal projects, they in fact affect the entire University.  This is because all University accounts are used in the calculation of the Federally Negotiated Indirect Cost Rate and because the standard requires consistency.  To be consistent with how costs are allocated to Federal projects that require costs be allocated consistently to all activities of the University.

  CAS 502: Consistency in Allocating Costs Incurred for the Same Purpose

  Purpose:To avoid overcharging of some cost objectives and to prevent double counting, which can occur when cost items are allocated directly to a cost objective without eliminating like cost items from indirect cost pools which are allocated to that cost objective.

  Objective:To set forth the University’s cost accounting practices with regard to distinction between direct and indirect costs.  For those types of cost which are sometimes accounted for as direct and sometimes as indirect, we must set forth the specific criteria and circumstances for making such distinctions.  These guidelines are intended to assist principal investigators, department heads, and administrators with their responsibility for compliance with this standard.

  Definitions:

  Direct costs (Uniform Guidance) are those costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity that can be directly assigned to such activities relatively easily with a high degree of accuracy.  When a cost is assigned to more than four (4) cost objectives, a high degree of accuracy is not possible, and, therefore, is an indicator that the cost should be an indirect rather than a direct charge, i.e., charged to a departmental account.

  Indirect costs (A-2 1, Section E.1) are those that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, and instructional activity, or any other institutional activity.

  EXAMPLES:

  Normally Direct	Normally Indirect
  Technical Staff Sal.	Admin/Clerical Staff
  Lab Supplies	Office Supplies
  Telecom toll charge	Basic Phone Service
  Animal care cost	Postage
  Consultants	Accounting services
  Specialized services	Purchasing services
  Subcontracts	Operation/Maintenance
  Dept. Admin	Buildings
  Project Travel	Renovations
  Proposal Cost	Library Expense

  CAS 505: Defines Unallowable Costs

  The purpose of CAS 505 is to set forth guidelines for identifying in the contractor’s accounting records specific costs that are unallowable and the cost accounting treatment of such costs.  Examples of unallowable costs include: disallowances, entertainment costs, and lobbying activities.  These unallowable costs must be excluded from all cost pools which may be passed on to the Federal Government, e.g., in the indirect cost proposal or in the billing rates of 2-1 Fund accounts.

  CAS 506: Consistency in Cost Accounting Practices when Estimating, Accumulating, and Reporting Costs

  The purpose of CAS 506 is to ensure that a University uses its normal fiscal year as its cost accounting period, with costs charged in the correct periods.

  Cost Principles

  Introduction – This section of the college manual will expand on specific cost accounting issues as they relate to sponsored projects as a result of Federal guidelines.  A more complete discussion of sponsored project financial issues is contained in the Sponsored Programs Manual published by the Office of Sponsored Programs.  The Cost Accounting Standards (CAS) for educational institutions were developed by the federal government to achieve consistency in cost accounting practices across all universities involved in federally sponsored programs.  January 9, 1995, the top 99 schools in federal research volume became subject to CAS requirements to submit a Disclosure Statement (Colorado State University ranks 74).  The Disclosure Statement is a comprehensive description of CSU’s accounting practices.

  Federal Guidelines – Circular A-21, issued by the Office of Management and Budget, is the document that provides one set of cost principles, which was developed to provide guidance to Federal agencies.  Circular A-21 established principles for determining costs which are allowable on grants, contracts and other agreements with educational institutions.

  Cost Principles (Uniform Guidance) – There are several fundamental provisions governing the application of cost principles:

  1. Sound management practices must be used. Ample documentation is important and should adequately elucidate the purpose and benefit to the project for any expenses charged.
  2. Discretion in incurring a cost chargeable to a federal award must be applied. Costs must be necessary for the completion of the sponsored agreement.
  3. Proportionate benefit must be “approximated through the use of reasonable methods” (i.e., a reasonable basis reflecting use or level of service). Costs should be earmarked to the “users” in proportion to the benefits received.
  4. Costs relevant to one award or activity may not be charged or transferred to another award or activity. It is not allowable to move expenditures from Project A to Project B in order to eliminate an over-expenditure on Project A.  It is not allowable to move expenditures from Project A to Project B in order to utilize remaining funds in Project B, which is ending.

  Quick Guide for Unallowable Expenses

  Reconciling Appropriated Funds:The Warner College of Natural Resources Business Office is responsible for reconciling all appropriated funds.  They are required to reconcile the accounts every month against the Kuali Financial System reports.  The departments must retain all financial records and should be filed in a manner that permits an orderly and timely retrieval (see Financial Policy and Procedure Manual at http://busfin.colostate.edu/fpi.aspx for additional information).  All changes to the Kuali Financial System are approved through the Dean’s Budget office.  A memo should be submitted to the budget section of the department for all expense corrections and/or budget redistributions.  The memo should include a detailed explanation for the requested change and a copy of the original document where appropriate.  All requests for corrections need to be requested immediately upon discovery of the error.  Sometimes we can make corrections before the entry has been processed through the Kuali Financial System.

  Proposals/SP-1:A proposal is an agreement between a sponsor requesting research, the principal investigator and CSU.  Principal Investigators (any CSU non-temporary, salaried state classified, or general faculty employee, including transitional appointments) should communicate their intent to submit a proposal at the earliest possible date to the Department Head, Dean’s office and to Sponsored Programs.

  Early planning is strongly recommended.  Preparation of the proposal should include the following:

  • Direct costs – Salaries, Wages, Benefits
  • Travel – field work and data collection, professional meetings, conference fees and registration, etc.
  • Materials and Supplies
  • Other direct costs – Animal care, computer use, consultants, photographic services, etc.
  • Participant support – stipends, tuition and fees
  • Subcontracts
  • Equipment
  • Indirect costs
  • Total project costs – direct + indirect costs

  After completion, the proposal is forwarded to Sponsored Programs.  Sponsored programs must have this proposal for review five days prior to the sponsor deadline.

  All proposal documents are to be kept a minimum of three years after the project is officially closed.

  Colorado State University takes pride in its long history of teaching, research, and service to the community and state. The tradition of research and service can be traced back to the University’s earliest beginnings and continues today with Colorado State’s reputation as one of the major research institutions in the United States. As primary coordinating office for externally-funded activities, Sponsored Programs represents the University serving those involved in sponsored contractual activities. Among the services provided by Sponsored Programs are:

  • Assisting faculty in locating funding opportunities
  • Reviewing, approving, and submitting proposals
  • Negotiating awards, material transfer and non-disclosure agreements
  • Administrative management of awards, including compliance issues, invoicing, financial reporting, project close out and record retention

  Please see the Office of Sponsored Programs for more information.