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.
Prior approval from awarding agency is required for items with a unit cost of $5,000 or more.
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.
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.).
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.
Computers do 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.