Ugh…you are a busy professor, checking through your email on a hectic day. There are urgent emails from students, colleagues, collaborators – and then, right in the middle, you see a request from your Sponsored Program Officer. “I see that you are trying to purchase [alcohol? printer ink? a working lunch? etc.] on your sponsored project. Give me a reason why you should be allowed to do this, or I am disallowing this cost right now, causing weeks of clean-up and delays to your research.”
Well, your Sponsored Program Officer will not be that blunt (hopefully). But no matter how friendly and polite this request might be, many PIs see such requests as unreasonable administrative burdens. I recently was forwarded an email from the chair of a department literally said: “Our Office of Sponsored Programs increasingly wants to know how we spent every penny of this money.”
Okay, so maybe that’s not totally fair – but these requests can pile up! That’s why the goal of this post is to fill you in what your friendly research administrator really asking you about the purchase, so you can quickly meet their request and get on with your life. Hit all five of these points, and you will most likely avoid a prolonged back-and-forth tug-of-war with your Sponsored Programs Office.
- Is this purchase allowable? Ick, what does “allowable” even mean? Broadly speaking, an allowable purchase does not violate general federal or specific sponsor requirements for what is permissible on a project. For example, alcohol (for social purposes) is not allowed on a federally sponsored project. Period. Taxpayers do not want to pay for your booze. That piece of equipment necessary for your work? Allowable. This link will take you to a fairly good, abbreviated list of unallowable costs, though everything is a bit up in the air with Uniform Guidance. Was the item in question specifically approved in the awarded budget? Then it is most likely allowable, no matter what the sponsor’s regulations typically are.
- Is this purchase allocable? If you buy something on a sponsored project, it should be for that project only. Want
to buy beakers, to be used by your entire lab on a variety of projects? That will not fly. The sponsor wants to pay for a specific scope of work to be conducted, and is not interested in funding other scopes of work. Are the beakers going to be used exclusively on your sponsored project? You are good to go. Buying a huge piece of equipment right before the project ends? The sponsor will obviously think this equipment is really for other projects, and might not be pleased with the last-minute splurge.
- Is this purchase reasonable? This requirement is so vague, but it essentially boils down to this: Would a reasonable person, using their own funds, purchase this item at this price for this scope of work? An obvious example would be two similar supplies, with one being far more expensive than the other. A reasonable person would choose the cheaper supply. Another example? Just because you are using sponsor funds does not mean you should travel first class to a conference.
- Is this purchase covered by F&A? Books, clerical salaries, computers, printers, paper, folders – purchasing any of
these will raise red flags with your Sponsored Programs Office. All of these items should be recovered by the F&A costs your project is recovering. If you make such purchases, it can look like you are “double-dipping.” Is this an essential purchase, and allocable to the project? Your purchase might be okay, though your Sponsored Program Officer will need to make that determination.
- Is this purchase going to overspend the project? Sponsored Program Officers will often ask for purchase approval if your project is over-budget or over-committed (will be over-budget if you continue spending the way you intended to currently). Except in rare circumstances, any costs above and beyond the awarded budget will be disallowed.
Work closely with your research administrator on these justifications – I have actually disallowed very few costs in my time, where the PI could provide a justification answering all of these questions. We want to keep your research moving, but also want to make sure the sponsor has no reason to disallow your purchases after the project has ended! Because that is way worse, in the long run, I promise!