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Responsibility for Compliance

Principal Investigator

Responsibility for scientific and budgetary decision-making in Federal Sponsored Awards and for following the University of Florida guidelines is assigned to the Principal Investigator.  The Principal Investigator is responsible for giving the college, department or division instructions on specific allocation of funds.  Such instructions must comply with the guidance outlined in this document.

College/Department/Division

The college, department or division is responsible for implementing and monitoring compliance with these guidelines.  They are also responsible for providing Principal Investigators with the information necessary to fulfill their fiduciary and sponsored award management responsibilities.  The college is responsible for clearly delineating the division of responsibilities between the college and its departments and divisions.  The college, department, or division must maintain documentation that will permit auditing by internal or external auditors.  This documentation should be stored in institutional systems (i.e. attached to the voucher in myUFL), rather than in local systems, wherever possible.

University of Florida

The University accepts responsibility for creating uniform rules of conduct relating to management of sponsored programs and assuring compliance with the rules of such programs.  No matter how flexible, these guidelines will require substantial attention and effort in their implementation.  The University of Florida’s administration realizes that day-to-day responsibility for compliance rests with the Principal Investigators and unit fiscal personnel.

The University accepts responsibility for developing a set of operating principles and guidelines that comply with federal regulations, and that among other things, clearly delineate those sponsored program expenses it identifies as direct costs and indirect costs.  It takes responsibility for disseminating this information to all University of Florida faculty and staff, whether their work is supported by governmental or non-governmental sources.  The University administration takes responsibility for overseeing the implementation of these principles and guidelines.

Division of Sponsored Programs

The Division of Sponsored Programs supports the University in its mission to ensure fiscal integrity by reviewing all requests for exemptions allowing normally indirect costs to be charged directly.  The Division will engage in creation and update of all policy and procedures regarding Cost Principles.  The Division will assist in the development of training and educational materials related to Cost Principles.

Contracts & Grants Accounting Services

The Office of Contracts & Grants Accounting Services (C&G) supports the University in its mission to ensure fiscal integrity by reviewing all transactions posted to sponsored awards at least annually.  C&G will engage in creation and update of all policy and procedure regarding Cost Principles and will assist in the development of training and educational materials related to Cost Principles.

Office of Cost Analysis

The Office of Cost Analysis supports the University in its mission to ensure fiscal integrity performing quality assurance reviews of departments and the University’s fiscal transactions.  The department reviews items of cost to allocate to the appropriate cost pools during the indirect cost proposal development.  Cost Analysis will engage in creation and update of all policy and procedures regarding Cost Principles and assist in the development of training and educational materials related to Cost Principles.

Definitions

Direct Costs

Costs that can be identified specifically with a particular sponsored award, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.  Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect costs.  Where an institution treats a particular type of cost as a direct cost of sponsored awards, all costs incurred for the same purpose in like circumstances shall be treated as direct costs of all other activities of the institution.

Documentation

Detailed explanation and support documents as evidence to substantiate allocability, allowability, and reasonableness for a specific transaction.

Indirect (F&A) Costs

Costs incurred for common or joint objectives [of the University] and not readily assignable to a particular sponsored award, instructional activity or other institutional activity, without effort disproportionate to the results achieved.  “Facilities” is defined as depreciation on buildings, equipment and capital improvement, interest on debt associated with certain buildings, equipment and capital improvements, and operations and maintenance expenses.  “Administration” is defined as general administration and general expenses such as the director’s office, accounting, personnel and all other types of expenditures not listed specifically under “Facilities.”

Principal Investigator

This person bears the main responsibility for costs that are charged to a grant, contract, or cooperative agreement.

Last Reviewed

05/01/2020: reviewed content

Resources

2 CFR 200 Quick Reference Guide

Uniform Guidance 2 CFR 200

48 CFR 9905 – Cost Accounting Standards (CAS) for Education Institutions

Training

RSH260: Cost Principles

RSH206: Cost Principles Advanced Topics

RSH282: UFIRST Awards

RSH212: Post Award Overview

Contacts

Contracts & Grants: (352) 392-1235

Cost Analysis: (352) 392-5778

Division of Sponsored Programs: (352) 392-1582