Grant Reporting and Compliance

The spending of funds awarded by the federal government to Georgetown University is governed by 2 CFR §200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance or UG), published by the Office of Management and Budget (OMB). Costs charged directly to a federal award must be:

  1. Allowable under both the provisions of federal guidance AND under the terms of a specific award. They must conform to limitations or exclusions set forth in these principles or in the sponsored agreement as to types or amounts of cost items.
  2. Allocable, the expense can be associated to a project with a high degree of accuracy
  3. Reasonable, the cost reflects what a “prudent person” would pay in a similar circumstance
  4. Charged consistently as direct expense (versus an indirect cost).

An expense is a “direct cost” if that expense can be identified specifically with a particular sponsored project or other activity with a high degree of accuracy. “Indirect costs” (sometimes referred to as facilities and administrative (F&A) costs), are costs that benefit many activities (e.g. building operations and maintenance, administrative personnel including grant managers, IT expenses, security, etc.). F&A costs are recovered through the federally negotiated indirect rate.  Costs incurred for the same purpose in like circumstances must be treated consistently, as either direct expenses or indirect costs.

The Federal Sponsored Awards Expenditures Guideline provides general and specific guidance regarding allowability of charges to federal awards. There may be situations where a Principal Investigator (PI) and the Department / Grant Manager have questions or do not agree on the treatment of specific expenses. In this case the question should be sent to either the Office of Sponsored Research (OSR) or the Main Campus Research Services Center (MSRSC) (formerly OSP) as appropriate or the Office of Sponsored Projects Financial Operations.