Charging Computers to Sponsored Projects

Definition

Computing devices are defined in the Uniform Guidance, CFR § 200.1 as:

Computing devices means machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or "peripherals") for printing, transmitting and receiving, or storing electronic information.

Computers with a unit cost of less than $5,000 are controlled assets, are budgeted under Materials and Supplies, and fall under CFR § 200.453. Computers with a unit cost of more than $5,000 are considered capital equipment and are budgeted under Equipment and CFR § 200.439. Prior approval from awarding agency is required for items with a unit cost of $5,000 or more.

The term “computer” encompasses all information technology devises including high-end mainframes, minicomputers, personal computers, tablets, notebooks, iPads, docking stations and other peripheral devices, regardless of whether the item meets the $5,000 capital equipment threshold. Other computer related equipment includes printers, scanners, bar code readers, and connectivity devices (routers, modems, etc.).

Justification

Computers are viewed as “general use” business items and generally used for various activities such as instruction, research, administration, email and personal use and cannot be linked to one specific project. The federal government is sensitive to computer purchases on federal awards, thus it is important to ensure their allowability and allocability as a direct cost to sponsored projects before the purchase has been made.

Computer purchases being charged to federal funds should be:

  • Essential for the purpose of carrying out a specific aim of the funded project. The computer is to support the project’s programmatic activities, and it would not have been purchased other than to support the goals of the project
  • Above and beyond what is normally provided by the department for academic use, and
  • Charged to the grant in some reasonable projection related to how much it is used for that funded project (allocability).

Purchases of computers on federal funds should be driven by the need for the computer to conduct the research project. This should be included in the budget justification and the benefit should be easy to discern. The justification need not be very long, just briefly describing the purpose and benefit of the device on the project.

The computing device can be listed under supplies in the itemized proposal budget, but should also be identified separately in the proposal budget justification as to why it is essential and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the computing device. Written justification and approval are meant to prevent questions regarding the allowability of costs in the event of an audit.

In the event that an unbudgeted computing device is required after an award is funded, the department can work with the College Budget Officer prior to purchase to ensure that this purchase is properly documented.

Other Information

It does not become your personal property at the end of the project and its use must comply with university procedures regarding property. The device may be titled to the government, so it is important to be familiar with the project’s terms and conditions. When it is not titled to the government or with the sponsor, the device is the property of the university and should be retained by the department after the end of the award for ongoing research activities, or for disposal in accordance with university policies.

If a computing device expense is deemed unallowable at any time, the cost will revert back to the PI and the PI's department for recovery from a departmental account.

Most sponsors will not allow a computer purchase at the end of the project, and purchases made within six months of the project end date may be subject to higher scrutiny. Check with the College Budget Officer to see if this can be charged.

Additional information may be found in the UNT PI Handbook.