Updated guidance on allowability of COVID-19 testing on university funds

Health & Safety leadership and the Office of Sponsored Projects are providing guidance on the allowability of COVID-19 testing on university funds, including important information about the application of these costs to sponsored awards. Reminder: Any faculty, staff, and students who are required to test prior to leaving the U.S. should utilize university testing options, which are free to the community. See additional details and possible action items on this topic.

Health and Safety leadership has issued the following guidance:

• Effective January 21, 2022, the university will NOT reimburse for COVID-19 tests for incoming faculty, staff, students, and guests that are required to have a test to enter the U.S. per the CDC.
• Faculty, staff, and students who are required to test prior to leaving the U.S. should use university testing options, which are free to the community. (Visit yalehealth.yale.edu for more information.)
• Should you obtain an exception from the Controller’s Office for COVID-19 testing fees, any charges to non-sponsored funds for testing must use the Spend Categories for Travel Unallowable (SC749 domestic or SC744 international). If applying the expense to sponsored funds, different Spend Categories are required – see below.     

The Office of Sponsored Projects has issued the following guidance:

Federal grants and contracts

• Based on NIH guidance, COVID-19 tests are an F&A cost when travel is not mandatory (Zoom can be utilized) and work on the projects has been getting done throughout the pandemic (no work stoppage).  Therefore these will normally be unallowable expenses on Federally sponsored awards. 
• All COVID-19 tests require prior approval – first from the Controller’s Office and then from the Federal sponsor – in order to be expensed to a Federal award. Use Spend Categories SC748/SC743 for Travel International or Domestic – Other.

Non-Federal grants and contracts

• Prior approval from the Controller’s Office is required. Prior approval from the sponsor is not required. Use Spend Categories SC748/SC743 for Travel International or Domestic – Other.

All sponsored funding

For both Federal and non-Federal sponsored funding sources, the following conditions would also apply:

• The award terms and conditions and sponsor’s policy allow the cost. (The most restrictive rule applies.)  
• The charge can be allocated to the cost of the project with a high degree of accuracy.  
• The amount charged is reasonable.
• The cost of the charges do not affect the researcher’s ability to complete the scope of work as intended.

Please utilize free testing through Yale or local pharmacies when possible before charging any sponsored award. It is important to document any testing requirements, the local travel restrictions, and fully justify all costs for audit purposes. 

For questions on health and safety guidelines regarding COVID-19, please use the contact information found on the Yale’s COVID-19 website. For questions regarding sponsored funds, please consult the OSP portfolio contacts.