28 CAPTURE. COSTTREE 2016 Q3 ISSUE
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Q: Is it allowable to purchase an item (equipment) through one project’s funds, and allow it to be used by a second project?
This is an issue that should be addressed in the grantee or subgrantee’s system of internal
controls. The project for which the equipment was purchased must have primary access to, and use of the equipment. However, when not being used for that project, it can be used for another Federally-funded project. If a grantee wishes to use equipment for two projects and wants to fund the equipment purchase from two separate Federal grants, the direct charge to each grant must only reflects the relative proportionate share of acquiring the equipment; i.e., if each grant paid for half the cost of acquiring the equipment, then each project could use it equally.
However, if the grantee has authorization from the respective Federal funding sources and it is
agreed that an equipment purchase serves the same cost objective of both grants, then the grantee may establish a “blended” accounting code for the purchase.
2
Q: The Guidance raises the threshold for reporting questioned costs to $25,000. Does that mean no questioned costs under that threshold will be reported?
The Guidance requires all questioned costs of $25,000 or more to be reported (2 CFR
200.516(a)(3)). However, auditors have the option of reporting questioned costs of lesser amounts.
3
Q: Are the cost principles in the Uniform Guidance for all types of recipients?
Generally, yes the cost principles are the same for all types of recipients: State, local, and Indian tribal governments; nonprofit organizations; and institutions of higher education. Where rules are entity-specific, the section or paragraph that specifies a different principle for one type of entity makes that applicability clear.
Most of the cost principles that apply to only one type of entity are those regarding indirect costs. See, for example, Appendices III-IX..
WITH AUDITORS
4
Q: How long can grantees charge the temporary ICR?
The temporary rate predates the new indirect cost flexibilities in the Uniform Guidance. Generally, a grantee can charge the temporary rate up to 90 days after the grant award date.
However, if the grantee does not submit an ICR proposal to the Department within that 90 days, the grantee can no longer charge indirect costs to the grant until the grantee obtains a negotiated ICR from ED. If the grantee submits its ICR proposal on a timely basis, then it may continue charging its grant at the temporary rate until it obtains a negotiated rate.