1305 PR.04 Unallowable Costs

Revision Date: 
October 2, 2018

Contents

  1. Overview
  2. Procedure Applicability
  3. Common Unallowable Expenses
  4. Unallowable Activities
  5. Office of Management and Budget’s (OMB) General Provisions for Selected Items of Cost
  6. Year-End Closing

The purpose of this procedure is to describe the treatment of unallowable costs for all University accounts and sources of funds (not just for sponsored awards)

Consistent assignment of charges to specific expense types enables the University to appropriately capture and exclude unallowable costs as a direct cost as well as from the federal Facilities & Administrative (F&A) rate proposal and subsequent reimbursement when the F&A rate is applied to sponsored awards.

Definition:

Unallowable costs: Those expenses incurred by the University which are not reimbursable by the Federal Government either as a direct or F&A type cost.

The following University entities must apply the federal costing regulations contained in 2 CFR Part 200, Subpart E for classifying their expenses:

  • schools and departments that have federal awards; and
  • departments that charge for goods or services, or are included in the Facilities and Administrative (F&A) cost rate calculation, such as administrative departments, facility departments, computing departments, the library system, health services, and other service departments or internal service providers.

Business Meals, Catering, Food & Beverages and Alcoholic Beverages

In order to comply with Federal Regulations when charging non-sponsored funds, the total costs of these types of expenses, including the cost of alcoholic beverages, are to be charged to the following spend categories: 

Spend Category (SC)

Spend Category Name

SC249

Group Meals and Food (Business Meals, not including travel)

SC258

Travel – Unallowable

SC256

Entertainment and Alcohol

When using any of the above SCs for a sponsored award, it is necessary to identify the cost of any alcoholic beverage and charge it to a non-sponsored award using SC258 for either domestic or foreign Entertainment and Alcohol expenses because alcoholic beverages cannot be directly charged to sponsored awards.

Travel

2 CFR Part 200.474 describes the basis for and the types of business travel costs appropriate to charge to federal awards.  Such costs include, but are not limited to, lodging and subsistence and commercial air travel with certain restrictions (e.g., least expensive available airfare with only certain exceptions as noted in 2 CFR Part 200.474).

University Policy 3301 Travel on University Business sets forth certain instances for International Travel where business class fares are acceptable.  In such cases, the excess amount over the coach fare price must be charged to SC258 – Travel - Unallowable

Travelers are encouraged to use the University’s preferred travel supplier Egencia by contacting them directly.  Travelers and arrangers will be able to take advantage of a complete offering of travel options and discounts; including University negotiated rates and low service fees.  If this preferred travel supplier is not used or the lowest available airfare is not obtained, the department will be responsible for substantiating compliance with the federal regulations.

Use SC258 for all unallowable travel costs, domestic or international.

Other Common Unallowable Costs

Spend Category

Spend Category Name

SC191

Internal Expense – IT Hosting and Platform Admin

SC190

Internal Expense – IT On Demand Services

SC194

Internal Expense – IT Portfolio Projects – Central

SC195

Internal Expense – IT Portfolio Projects – Client

SC193

Internal Expense – IT Support Agreements

SC196

IT Services

SC647

Pass-through Yale Labor Cost Allocation

SC192

Telecommunications Expense

SC199

Services – Student

SC406

Advertising – Electronic

SC405

Advertising – Print Media

SC121

Collections Rare Archives – Mixed Format

SC120

Collections Rare Graphic Materials

SC122

Collections Rare Manuscripts

SC670

Collections Rare Maps

SC118

Collections Rare Monographs

SC119

Collections Rare Other

SC669

Collections Rare Serials

SC127

Collection Art and Museum Acquisition

SC258

Travel – Unallowable

SC233

Professional Services Fees – Unallowable

SC292

Losses

SC189

Materials for Resale

SC293

Prizes & Awards

SC273

Commissions

SC383

P-Card Write-Offs

SC296

Subsidies

SC295

Community Support

SC275

Dues & Membership – Unallowable

According to 2 CFR Part 200, Subpart E, certain activities are unallowable both as a direct and a F&A cost such as lobbying (review lobbying primer), alumni activities, investment activities, commencement activities, and fund-raising activities.  Charges associated with any of these “unallowable” activities should be charged to the appropriate unallowable spend category.  For example, engaging an external consulting firm or consultant to lobby for federal funds is an unallowable activity.  Since there is not a Lobbying expense type the cost of engaging the consultant would be charged to SC233.

Most employees in schools and departments are not typically involved in these “unallowable” activities. However, for faculty and staff who are involved, salaries (including miscellaneous payroll) and associated compensation should be charged to the appropriate spend category for unallowable salaries and wages. 

Note:  Any travel related to such activities must be coded to SC258 as appropriate for all related unallowable travel costs (domestic or international).

If a department incurs an expense considered to be an “unallowable” activity, the department must contact the Associate Controller, Costing in writing (e-mail: anne.navin@yale.edu) so that a determination can be made regarding the proper treatment of the costs associated with this activity to ensure its exclusion from the calculation of the F&A rate.

2 CFR Part 200, Subpart E provides principles to be applied when establishing the allowability of certain items of cost.  These principles should apply irrespective of whether a particular item of cost is properly treated as a direct cost or a F&A cost.  Failure of OMB to mention a particular item of cost is not intended to imply that it is either allowable or unallowable; rather, determination as to allowability in each case should be based on the treatment provided for similar or related items of cost.  In case of a discrepancy between the provisions of a specific sponsored agreement and the list below, the agreement would govern.  Click here to review the definition of each cost Item and its applicability and allowability.

2 CFR 200 Section

Cost Item

200.421

Advertising and Public Relations

200.422

Advisory councils

200.423

Alcoholic beverages

200.424

Alumni/ae activities

200.425

Audit services

200.426

Bad debts

200.427

Bonding costs

200.428

Collections of improper payments

200.429

Commencement and convocation costs

200.430

Compensation - personal services

200.431

Compensation – fringe benefits

200.432

Conferences

200.433

Contingency provisions

200.434

Contributions and donations

200.435

Defense and prosecution of criminal and civil proceedings,

claims, appeals and patent infringements

200.436

Depreciation

200.437

Employee health and welfare costs

200.428

Entertainment costs

200.439

Equipment and other capital expenditures

200.440

Exchange rates

200.441

Fines, penalties, damages and other settlements

200.442

Fund raising and investment management costs

200.443

Gain and losses on disposition of depreciable assets

200.444

General costs of government

200.445

Goods or services for personal use

200.446

Idle facilities and idle capacity

200.447

Insurance and indemnification

200.448

Intellectual property

200.449

Interest

200.450

Lobbying

200.451

Losses on other awards or contracts

200.452

Maintenance and repair costs

200.453

Material and supplies costs, including costs of computing devices

200.454

Memberships, subscriptions and professional activity costs

200.455

Organization costs

200.456

Participant support costs

200.457

Plant and security costs

200.458

Pre-award costs

200.459

Professional service costs

200.460

Proposal costs

200.461

Publication and printing costs

200.462

Rearrangement and reconversion costs

200.463

Recruiting costs

200.464

Relocation costs of employees

200.465

Rental costs of real property and equipment

200.466

Scholarships and student aid costs

200.467

Selling and marketing costs

200.468

Specialized service facilities

200.469

Student activity costs

200.470

Taxes (including Value Added Tax)

200.471

Termination costs

200.472

Training and education costs

200.473

Transportation costs

200.474

Travel costs

200.475

Trustees

Unallowable costs at fiscal year-end that are not identified with the correct unallowable ledger account must be reclassified.  This action must be completed by the first close of the June period. (Contact the Controller’s Office for the current year-end closing schedule.)