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  • Open Comment Period: May 4 - May 15, 2015

    May 4, 2015 8:30 am by OBFS Policy Administrator

    In this Open Comment: Section 22 - Charge Self-Supporting Goods and Services to Sponsored Project Funds

    A new policy and procedure will be in place for charging self-supporting goods and services to sponsored project funds. This change is to comply with the new policy from the Federal Office of Management & Budget, titled "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" (also called OMB Uniform Guidance). Please review the new section titled "Charge Self-Supporting Goods and Services to Sponsored Projects" and provide comments.

    Please review this policy and submit your feedback. Thank you!

    Charge Self-Supporting Goods and Services to Sponsored Project Funds

    Before You Begin
    Federal sponsored project guidelines limit the timeframe in which charges to a sponsored award must be posted following the close of the funded activity’s performance period (Code of Federal Regulations §200.343). Some sponsors also limit the billing timeframe for each budget year within a multi-year project. Timely billing of University internal charges to sponsored project funds is necessary to assure that the sponsor will reimburse all charges.

    To comply with this requirement, any self-supporting activity that provides goods or services to a sponsored project must bill the related project fund monthly. Units with sponsored awards that require billing all project costs within thirty days of closing the project must notify related self-supporting activities of the billing deadline, and the self-supporting activity must then bill the project for all related goods and services before that deadline.

    Unreimbursed charges must be paid by:

    • The unit that operates the self-supporting activity, when that unit failed to bill within the required timeframe
    • The unit that requested the service, when that unit failed to notify the self-supporting activity of more stringent billing deadlines, or provide other needed billing information, such as the C-FOAPAL.

    Units may negotiate who pays unreimbursed charges when responsibility is shared.

    Banner program code designated for exclusion from campus indirect cost studies.  The self-supporting activity cannot recover the unreimbursed charge from future charges for goods or services or otherwise absorb the charge, such as by only reversing the billing and related revenue. If the responsible unit does not have any state, institutional, or gift funds, contact OBFS University Accounting and Financial Reporting to discuss options.

    Begin
    To charge self-supporting goods and services to sponsored project funds:

    • Determine whether the activity’s customer base includes charges to sponsored project funds.
    • If the activity will charge a sponsored project fund currently or in the future, implement billing procedures to assure charges are billed monthly.

    To leave feedback, please use the "Add Comment" link below. On the next screen, choose the "Sign in with my NetID" option and log in with your University credentials. Comment moderation is enabled. Your comment will not appear until approved.

    You may also submit a comment without posting to the feedback board by contacting obfspolicies@uillinois.edu.

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    Comments

    pczarn2@uic.edu Jul 29, 2016 2:26 pm

    Mandating that charges are to be processed within 30 days is not realistic for service center units who are already under staffed who process a large quantity. I believe increasing this to a 60 day window will allow sufficient time. You also need to have exceptions to this policy when a service center unit starts a service in advance of receiving the CFOAP while the contract is being negotiated.

    pczarn2@uic.edu Jul 29, 2016 2:26 pm

    I agree completely with the comments made by others.

    Requiring the unit responsible for a self-supporting activity to cover the cost of unreimbursed charges is a sufficient incentive to encourage timely billing, without having to impose a monthly billing mandate. Monthly billing is too labor intensive, and thus costly, to be workable in every situation. We would have to increase our charges quite a bit if we had to bill monthly.

    pczarn2@uic.edu Jul 29, 2016 2:26 pm

    It seems to me that requiring the unit responsible for a self-supporting activity to cover the cost of unreimbursed charges should be a sufficient incentive to encourage timely billing, without having to impose a monthly billing mandate. Monthly billing is too labor intensive, and thus costly, to be workable in every situation.

    pczarn2@uic.edu Jul 29, 2016 2:26 pm

    200.343 Closeout: This section deals with the closeout of an award. I am unclear why this section justifies the requirement that units bill back monthly throughout the grant period, in lieu of quarterly? For under-staffed units, this will be a burden. Requiring units to get final charges billed to the project within 30 days following close of the project, is reasonable.

    pczarn2@uic.edu Jul 29, 2016 2:26 pm

    The following statement requires monthly billing: "To comply with this requirement, any self-supporting activity that provides goods or services to a sponsored project must bill the related project fund monthly." This would require a significant amount of work from a large fiscal and clerical staff and therefore is cost prohibitive.