Cost Accounting Guidelines: Executive Summary

For awards made before 12/26/14 which are not subject to the Uniform Guidance

Replaced by new guidance - 11/25/2014

Principal Investigator's Guide to Purchasing Computers and Electronic Devices on Grants

Computers and electronic devices are typically used for many different activities, including instruction, research, administration, email, and personal use. Thus, the Federal government argues that those items are not used solely to support the research objectives of any specific sponsored project and are not appropriate as direct charges to sponsored projects. Therefore, general purpose computing support is considered to be an administrative cost that should normally be covered by F&A reimbursement.

It is possible to obtain approval for an exception to the standard Federal principles that apply to costs. When appropriate, the responsibility for review and approval of an exception resides in the office of the dean or director of colleges and schools at UW-Madison, with review later by Research and Sponsored Programs.

The following principles must be met in order to receive approval for an exception on a Federal award:

  • The project needs justify use of the item in a way that is unlike typical purchases of the item.
  • The purpose and benefit to the specific project have been fully described in the exception request.
  • The project will be negatively impacted by not purchasing the computer or electronic device.
  • It has been approved by the sponsor or sufficiently justified and approved by the College or School.

Below are the basic principles for receiving approval for an exception on a Non-Federal award:

  • Written sponsor guidelines do not prohibit the purchase of computers and electronic devices.
  • The costs must be directly allocable to the project that purchases the equipment.
  • The purchase must represent good stewardship of the sponsor’s funds and the project’s stated objectives.
  • The costs are reasonable and directly benefit the sponsor’s project.
  • All other sponsor required stipulations apply (i.e. rebudgetting tolerances, notifications, etc.)

For both Federal and Non-Federal sponsors, if a computer or electronic device is 100% funded from a sponsor, the device cannot be used for purposes outside the goals of the project on more than an incidental basis. Generally, incidental usage means no more than 5%. Criteria for incidental use include:

  • Incidental use never interferes with project use.
  • Incidental use is solely for efficiency, such as responding to non-project related e-mails in a timely manner.
  • Incidental use itself would not have justified purchase of the laptop or device.
  • Incidental use does not exceed a de minimis amount of 5%.
  • Generally, non-project files or data are not stored on the computer.
  • The computer is not used for administrative support, such as purchasing and grant management.

If an approved exception is deemed unallowable at any time, the cost will revert back to the PI, the PI’s department/unit, and the college/school for recovery from an unrestricted source of funding.

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