Electronic Device and Reasonable Accessories Purchase Guidelines
OHSU policy requires SPA's practices, procedures and guidelines be designed to provide that costs charged to federal sponsored awards are reasonable, allowable, allocable and consistently applied in like circumstances.
Computers, peripherals, and electronic devices are generally considered F & A costs by the federal government. If electronic devices are to be purchased, it is recommended the items be written into the budget and include specific device utility, benefit to the project, and why the item is necessary to complete the scope of work. Inclusion in the budget does not guarantee items will be allowed by the sponsor.
In general, electronic devices are not an allowable direct cost.
Like all other direct costs per OHSU policy and SPA guidelines, electronic devices purchased on a grant should be based on actual incurred costs and their relative benefit to the project or activity. Since these items are now used for a wide variety of tasks, it has become increasingly difficult to separate project specific activities from general or administrative activities, thereby categorizing electronic devices as an F&A cost.
Through audit disallowances, policy manual revisions, responses to specific questions, excerpts in NGAs, presentations at professional conferences and the like, the Federal government has repeatedly stated electronic devices including computers, laptops, table computers, e-readers, PDAs, and smart phones, are generally not allowed as a direct cost. Such costs are considered administrative and funded through F&A recovery. Nationally, universities have followed suit by issuing additional internal guidance.
Computers, peripherals and other electronic devices used for purposes other than direct research, (i.e. OHSU business), must be allocated based on actual usage. If there is justification or reasonable explanation that indicates that the device is used solely for tasks required for the project, the device could be allowable. If a device is used on multiple grants, the cost must be allocated based on actual usage. If the device will partially be used for general administrative duties, the cost should be partially allocated to a GL fund. All charges must meet the tests of cost principles: reasonableness (the prudent person test), allocability (clear and direct allocation to the project), consistency in treatment for like situations, and conformance with award and institutional policies.
If funds are available, computers may be purchased on an NRSA Fellowship under the Institutional Allowance, which is not accounted for on a cost-reimbursable basis. However, fellows are not allowed to keep computers for personal use after the fellowship expires; the disposition of computers is subject to OHSU policy.
Program Development Accounts (PDAs) represent unrestricted funding for which the standard cost principles do not apply. PIs are encouraged to purchase computers from these funds.
Additional justification may be requested for purchases made in the last few months of a terminating award.
Contact your Sponsored Projects Analyst for additional information.
The NIH Grants Policy Statement states: "Office equipment (copiers, laptops, desktop computers, personal handheld computers, fax machines, scanners, etc.) that is used for general office purposes (rather than justified as a specific research purpose) are not allowable as direct costs; they are allowable as an F&A cost."
The NSF Grant Proposal Guide II. 2. g states:"The cost of computer services, including computer-based retrieval of scientific, technical and educational information, may be requested only where it is institutional policy to charge such costs as direct charges. A justification based on the established computer service rates at the proposing organization must be included. The proposal budget also may request costs for leasing of computer equipment. General purpose (word processing, spreadsheets, communication) computer equipment should not be requested. Special purpose or scientific use computers or associated hardware and software, however, may be requested as items of equipment when necessary to accomplish the project objectives and not otherwise reasonably available."
- Findings of HHS' 1/16/09 audit of Duke University resulting in $1.7M of disallowances: "The University charged an NIH-funded project $3,364 for a laptop computer and asserted that the computer was used solely for project data and allowed the employee "the opportunity to work from home or wherever she may be located at anytime of the day." We noted, however, that the involved employee was budgeted to devote only 5 percent of her University time to the project charged for her computer."
- Statement from a NIH NOA where the budget included computers and peripherals purchases: "Funds requested for the following items are generally considered F&A costs: laptop computers, touchscreen monitors, server, and wireless hub. Therefore, the allowability of direct cost charges to this project for these purposes is predicated on the awardee's compliance with the provisions of applicable OMB Circulars."
- From a NIH Compliance Officer: "Unless specifically justified for a special research purpose, laptops or computers are a 'general use' business item and so are treated as an administrative (F&A) cost. Costs of laptops/computers reside in either the category of general purpose equipment or general purpose supplies, depending upon the price of the laptop/computer and the organization's capitalization threshold. The purchase of laptops/computers must be justified for a special research purpose in order to the charged as a direct cost to an award. General office use-writing manuscripts, communicating and such do not provide sufficient justification."
Electronic device usage likely to be allocable:
- Controlling an instrument/attached to equipment
- Data analysis/manipulation
- Extensive project specific data storage on an active award
- Image/video analysis
- Field work/on-site research subject data accumulation
- Building databases/writing code
- Extensive web design
Electronic device usage likely to be considered general purpose:
- Proposal preparation
- Exclusively for preparation of manuscripts/presentations/progress reports
- Administrative duties such as checking email, ordering supplies, or running OGA reports
- E-reader for scientific journal articles/books
- Internet research
- Personal use