Funding Transition Updates: Please see Federal Transition Updates 2025 for the latest federal executive orders and research activities.
Award Expenditures
Sponsor-approved research is accomplished through personnel effort, goods and services, collaborations, and other activities that result in expenditures. The Uniform Guidance defines such expenses as charges made by a recipient or subrecipient to a project or program for which an award has been received. Accordingly, all expenditures must be consistent with the statement of work and incurred within the project period.
Charging expenditures to sponsored projects carries significant responsibility. At GW, Principal Investigators (PIs) and research support staff are required to ensure compliance and accountability when requesting or approving expenditures.
The following guidelines, based on the Uniform Guidance, should be applied to all expenditures.
- Is the cost allowable?
Is the cost permissible, or is it prohibited by applicable laws, regulations, sponsor guidelines, GW policies, and award terms?
Under special circumstances, a cost generally disallowed by agency guidelines may be permitted by specific award terms or vice versa. In such cases, one must review the explicit terms or restrictions stated in the award agreement before approving the expense.
For example, while research related to travel may be allowed under general agency guidelines and is not prohibited by GW, it cannot be charged when restricted by a specific term in an award.
- Is the cost allocable?
Is the cost incurred specifically for the award research and charged in proportion to the benefit of the award’s research?
A cost allocable to a particular federal award may not be charged to other federal awards to overcome fund deficiencies or to avoid sponsor restrictions.
A cost must never be allocated to a project solely based on the availability of funds; a remaining award balance is never a valid justification for charging an expenditure to an award.
Additionally, costs benefitting two or more projects or activities are allocated in proportional benefit and must include reasonable documentation. However, under certain circumstances, such as the purchase of equipment or other capital asset specifically authorized under a federal award, the costs are assignable to the federal award regardless of the use that may be made of the equipment or other capital asset involved, when no longer needed for the purpose for which it was originally required.
- Is the cost reasonable and necessary?
Is the cost required for the efficient performance of the research and amount charged reasonable and justifiable?
The expenditures must reflect actions a prudent person would take under similar circumstances and be charged in a manner consistent with GW practices.
The GW Procurement and Travel should be consulted for purchases at competitive prices while ensuring the necessity for the expense.- Is the cost charged consistently by the grantee?
Is the cost being uniformly applied to all sponsored project activities?
A cost must not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
The Checklist for Direct Charging Administrative Costs to Sponsored Projects should be consulted for special circumstances.
- Is the cost adequately documented?
Does the documentation provide reasonable assurance that the cost complies with the award’s terms and conditions?
Accurate, detailed, and complete documentation must be submitted to reviewers responsible for approving the expenditure. If requested, the expense submitter must provide additional information to the approver to ensure an informed decision.
Sponsored project expenditures are managed collaboratively by GW offices and teams. Budget cost categories should be referenced to develop a clear understanding of how to appropriately charge expenditures. In addition, PIs and designated RST personnel must conduct regular, ongoing monitoring of expenses to ensure compliance with the terms and conditions of each agreement.
Below are examples of generally allowable expenditures, along with links to the corresponding GW offices and their guidelines. The list is not exhaustive and award-specific terms and restrictions must be consulted before charging expenses.
Compensation
- Human Resource Management and Development
- Grants and Contracts Accounting Services (GCAS)
- GCAS Labor and Effort Reporting
- Tax Department
Consultants
Equipment
Goods and Services
Participant Support Costs
Student Support
Subrecipients
Travel
Please note that alcohol, entertainment, advertising, and proposal costs are generally not allowable on sponsored projects.
Process
- The Principal Investigator (PI) is responsible for the effective management of the award, including ensuring the necessity and allocability of all expenditures charged to the award.
- The Research Support Teams (RSTs) serve as the points of contact for PIs and are responsible for reviewing expenditure allowability, assisting PIs with charging expenditures in GW financial systems, and approving expenditures.
- Questions or concerns related to the specifics of the financial management of an award are addressed by RST supervisors. Ongoing concerns are escalated by the RST supervisor to the OSP Award Management Specialist.
- Expenditures requiring prior approval from the sponsor are submitted by the RST via the Award Modification Request (AMR) in myResearch to OSP for review, approval, and submission.
Resources
- GW Award Management SharePoint Guide (GW Login Required)
- GW Chart of Accounts (GW Login required)
- Affiliated Offices
- GW Compliance: Research and Sponsored Project Policies
- PI Dashboard
- myResearch
- Uniform Guidance: Subpart E Cost Principles
Frequently Asked Questions
- Why does GW require supporting documentation for award expenditures?
The success of a sponsored project is contingent not only on the ability of the PI to carry out the project but also the university’s ability to provide proper stewardship of the awarded funds. Accordingly, GW is both required by the sponsor and committed to maintaining effective control and accountability for all expenditures charged to an award. Supporting documentation that demonstrates costs are allocable, allowable, reasonable and necessary is critical to ensure compliance, maintain accurate records at GW, and substantiate expenditures if requested by the sponsor.
- When can I direct-charge administrative costs to an award?
According to the Uniform Guidance, administrative costs should be treated as indirect costs. However, OSP provides guidelines for exceptional situations in which it may be appropriate to charge administrative costs directly to a federally sponsored project. For non-federal sponsors, the award’s terms and conditions are consulted to determine whether GW can direct-charge administrative costs to the award.
- What is meant by award expenditure types?
Expenses charged to sponsored projects are coded according to the expenditure categories reflective of the charge. GW’s Natural Account Structure provides brief descriptions for each account code to offer clarity and guidance. A GW login is required to view the grant expenditure types and corresponding account numbers. GW Office of the University Controller is responsible for the management and maintaining the accounting structure.
- What is suspense and what steps can be taken to clear transactions in suspense?
Transitions that cannot post to the award they were initially charged to, due to date or award status issues, roll into suspense. A GW login is required to access details related to suspense and the steps necessary for the efficient management of these transactions.
- What causes failed funds and how can they be managed?
Insufficient award balance generally results in failed funds. In such cases, expenses above the available balance must be moved off the award to resolve the failed funds. In instances when incremental funding is expected, an award may be placed at risk to allow research and expenditures to continue. The OSP Prior Approval page can be referenced for details on requesting advance at-risk accounts.
- What are the steps to correct an expenditure erroneously charged to an award?
GW requires regular, ongoing monitoring of award expenditures to ensure compliance with the terms and conditions of an agreement. In instances where an error is identified, the RST can initiate a cost transfer to correct the charge.