Electronics on Sponsored Projects

Guidance for the Purchase of Personal Computers and Electronic Devices on Sponsored Projects

Federal Guidance

The Uniform Guidance, 2 CFR §200.453, part (c), states:

In the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal award.

The following criteria will be used to determine whether or not a device is essential and allocable:

•The need has been included in the original proposal and completely justified as to the reason it is being included in the project budget.

•It has been approved by the sponsor as part of the budget and award process.

•The device is necessary for the performance of the project.

•The project will be negatively impacted by not purchasing the computer or electronic device.

•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 project that purchases the equipment.

Proposals

The device should be identified in the proposal budget and justified as to why it is essential and allocable to the performance of the award. Inclusion in the budget and budget justification is intended to enable the sponsor to review and concur with the need for the computing device. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in event of an audit.

Post-Award

Not every cost can be anticipated at the time of proposal preparation. When a post-award need for a computing device is identified and prior to its purchase, an explanation of the need should be submitted to the appropriate College/School research contact. The purpose and benefit of the device to the specific project should be fully described in the justification. Contact your Dean or Director's office regarding specific procedures on submitting such a justification.

If a computing device is purchased with sponsor or University funds, the device is the property of the University and should be retained by the department after the end of the award for ongoing research activities or for disposal in accordance with University policies.

If a computing device expense 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.