COST ACCOUNTING STANDARDS (CAS) TRAINING June, 2001

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COST ACCOUNTING STANDARDS (CAS) TRAINING 
June, 2001 

PRESENTED BY:  RITA JENSEN -  Administrator, Bioengineering TAMI SADUSKY -  Director, Grant and Contract Accounting JOEL SEARLES -  Associate Director, Grant and Contract Services KEN WELCH -  Senior Auditor, Internal Audit JANE WISEMAN -  Director, Management Accounting and Analysis ZENAIDA SHATTUCK - Audit Supervisor, Internal Audit  
 
 
 
 

CAS TRAINING - WHY??? 

University must comply with federal Cost Accounting Standards (CAS) in OMB circular A-21 UW Audit Risk: Greatest risk - Academic departments00nbsp; inconsistent treatment of costs  as either Direct or Indirect  
 
 
 
 

CAS BACKGROUND 

Four cost accounting standards were incorporated into OMB  Circular A-21 in 1996 University was also required to: Disclose  its accounting practices to DHHS   Demonstrate that UW accounting practices comply with the cost accounting standards in A-21  
 
 
 
 

HOW WAS CAS IMPLEMENTED AT THE UW 

Primary goal of CAS team: Retain flexibility for departments to continue accounting/operating practices Enable UW to comply with CAS  
 
 
 
 

HOW WAS CAS IMPLEMENTED AT THE UW (cont) 

To accomplish this goal, the CAS team met with academic departments to: Determine what existing accounting practices were in place Discuss how to structure required changes so departments could continue to run efficiently  
 
 
 
 

HOW WAS CAS IMPLEMENTED AT THE UW (cont) 

UW00 Disclosure Statement Audited by the Federal government to determine if our accounting practices complied with the four CAS standards November, 1999, UW00 disclosure statement was approved by DHHS  
 
 
 
 

HOW DOES CAS AFFECT UW? 

CAS standard that has the biggest impact upon the University: 00ll costs incurred for the same purpose,  in like circumstances,  are either direct costs only or F&A costs only00/font> Federal government concerns: That the same type of costs not be charged both directly and indirectly unless unlike circumstances exist  
 
 
 
 

HOW DOES CAS AFFECT UW? (cont) 

UW developed and revised policies as needed to comply with CAS GIM 23 - Costing Policy for sponsored agreements created GIM 21 - Cost Sharing on sponsored agreements was revised  
 
 
 
 

DIRECT COSTS 

Definition of direct costs in OMB Circular 
A-21 is: 00irect costs are those costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy00/font>  
 
 
 
 

WHEN CAN A COST BE DIRECTLY CHARGED? 

To directly charge  a cost,  it must: Be specifically identified to the work conducted under the project Provide explicit benefit for a specific programmatic purpose Be chargeable or assignable in accordance with the relative benefits received or other equitable relationship  
 
 
 
 

F&A OR INDIRECT COSTS 

Definition of F&A costs in OMB Circular A-21: 00&A costs are those that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity00/font>  
 
 
 
 

00ORMAL00 F&A OR INDIRECT COSTS 

00ormal00nbsp; facilities and administrative costs must be charged indirectly, unless: A level of service above the 00ormal00level is required by the sponsored agreement Special technical expertise or items are required by the sponsored agreement, which are not otherwise needed or available in the department A non-federal award allows the cost  
 
 
 
 

LIST OF 00ORMAL00F&A OR INDIRECT COSTS 

Administrative and Clerical Salaries Office Supplies Toner cartridges and diskettes Basic Telephone Services Includes installation, line charge, instrument Pagers and related service charges Routine copying charges Memberships Journals and subscriptions  
 
 
 
 

OFFICE SUPPLIES 

Binders Business cards Copy paper Diskettes (1.44 MB) Envelopes File folders and labels Letterhead Paper clips Pencils, pens, erasers  
 
 
 
 

OFFICE SUPPLIES (CONT) 

Post-its Push pins Rubber bands Rulers Scissors Staplers, staples, staple pullers Tape (scotch, masking, etc.) Telephone message pads  
 
 
 
 

DIRECTLY CHARGING 00ORMAL00F&A COSTS 

To directly charge 00ormal00F&A costs to federal awards, all of the following must occur: 00nlike circumstances00must exist Above 00ormal00level of services or items Technical expertise or items not otherwise needed by department Cost must: Be specifically identified to the work conducted under the project  
 
 
 
 

DIRECTLY CHARGING 00ORMAL00F&A COSTS (CONT) 

Provide explicit benefit for a specific programmatic purpose Proposal must include: The  00ormal00F&A cost in the budget of the sponsored agreement A sufficient explanation of the 00nlike circumstances00that exist to justify the direct charging of the 00ormal00indirect cost Modular grants require  justification in the file Sponsoring agency must accept the cost SPONSOR APPROVAL ALONE IS NOT SUFFICIENT  
 
 
 
 

00ORMAL00 F&A COSTS CAN ALSO BE DIRECTLY CHARGED IF: 

It is a non-federally sponsored agreement and directly charging the cost complies with the terms and conditions of the sponsored agreement Off-campus research can directly charge: Basic telephone costs Office supply costs  
 
 
 
 

EXAMPLES OF 00NLIKE CIRCUMSTANCES00/font> 

Sponsored agreement that requires a survey be sent to 2,000 participants can charge an administrative assistant00 time, paper, etc. needed to conduct a survey Sponsored agreement requires the assignment of a firefighter trained in handling flammable materials required by the sponsored award,  and this service is not otherwise needed or available in the department  
 
 
 
 

EXAMPLES OF 00NLIKE CIRCUMSTANCES00(CONT) 

Examples when administrative/clerical salaries can be directly charged: Large, complex programs, such as clinical research centers or program projects Grants/contracts that entail assembling and managing teams of investigators from a number of institutions Projects which involve extensive data accumulation, analysis and surveying, such as clinical trials  
 
 
 
 

EXAMPLES OF 00NLIKE CIRCUMSTANCES00(CONT) 
 

Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences Projects that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels and other remote research sites  
 
 
 
 

EXAMPLES OF 00NLIKE CIRCUMSTANCES00(CONT) 

Phone installation and line costs for a crisis line required by the sponsored agreement Copying of journal articles directly and solely related to the sponsored project A membership fee that lowers (and is less than the difference in) the conference cost for a conference specifically related  
 
 
 
 

EXAMPLES OF 00NLIKE CIRCUMSTANCES00(CONT) 

Cost of a journal specifically and solely related to the sponsored work conducted  
 
 
 
 

FACULTY EFFORT COST SHARING 

Faculty effort cost sharing changes that occurred to comply with CAS include: When faculty pledge effort without funding in the proposal, the budget number for that award prints in the cost sharing section of the faculty effort certification (FEC) form When faculty effort cost sharing is entered into the budget driver, it is coded as one of the following: M - Mandatory V - Budgeted Voluntary O - Other Voluntary C - Capped  
 
 
 
 

1/5/01 CHANGES TO COST SHARING  

Only report cost sharing effort that is: Mandatory Included in the proposal budget or budget justification Assumes that cost sharing will not be placed in other parts of the proposal (i.e. Narrative) Cost sharing is added to the organized research base to calculate F&A rates  
 
 
 
 

1/5/01 CHANGES TO COST SHARING (CONT) 

00ost00 federal awards should have faculty or senior researcher effort, either paid or unpaid Faculty salary paid by the sponsored project in summer quarter only satisfies this requirement Exception for some awards, such as: Programs for equipment and instrumentation Doctoral dissertations Student augmentation  
 
 
 
 

DISTRIBUTION OF COSTS BETWEEN TWO OR MORE GRANTS/CONTRACTS 

A-21 provides two methods for allocating an allowable direct cost to two or more sponsored agreements: the proportional benefit rate the interrelationship rule  
 
 
 
 

REBUDGETING TO DIRECTLY CHARGE A 00ORMAL00F&A COST 

Unlike circumstances must exist, and be documented in writing by the PI Documentation will be maintained in the departmental grant file Rebudgeting is allowed by NIH, NSF and ONR Other agencies require prior approval  
 
 
 
 

AUDIT ISSUES

 
 
 
 
 

GENERAL AUDIT OBJECTIVE 

To determine whether the systems of internal controls are sufficient to ensure compliance with federal regulations and university policies that pertain to the consistent treatment of costs  
 
 
 
 

AUDIT SCOPE 

IA reviewed controls at eight departments representing five colleges/schools Reviewed controls currently in place Testing concentrated on four categories of costs that are normally charged as indirect costs: Administrative and clerical salaries Office supplies Subscriptions Memberships  
 
 
 
 

OVERALL CONCLUSION/FINDINGS 

Controls were not sufficient to ensure compliance Findings Costs that should normally be treated as indirect costs were directly charged to federal projects and university requirements were not followed Costs were not included in the proposed budget  
 
 
 
 

FINDINGS (CONT) 
 

Proposals did not include justifications Budget justifications had inadequate explanations of the unlike circumstances requiring the direct charging of costs  
 
 
 
 

FINDINGS (CONT) 

When rebudgeting occurred, the need and exceptional circumstance for direct charging the costs were not justified and documented in writing by the PI Costs were not reviewed for allowability during the BAR reconciliation process Higher risk for unallowed charges for departments that permit students to place orders  
 
 
 
 

INTERNAL CONTROLS

 
 
 
 
 

AUTHORIZATION AND APPROVAL 

As part of proposal review and approval, departments should ensure that requirements under GIM 23 (costing policy for sponsored agreements) are being followed.  Specifically: Costs are specified in the proposed budget Exceptional or unlike circumstances requiring the direct charging of 00ormally00 indirect costs are justified in the proposal  
 
 
 
 

AUTHORIZATION AND APPROVAL (CONT) 

Departments should have clear understanding as to who in the department is responsible for reviewing proposals for accuracy and completeness  
 
 
 
 

AUTHORIZATION AND APPROVAL (CONT) 

Only individuals authorized by the PI to incur expenses for the project should approve the acquisition of goods and services Individuals should have direct knowledge of the needs of the project (see GIM 14) Individuals should know which cost categories can be charged to the budget  
 
 
 
 

REVIEW AND RECONCILIATION 

Purchasing and payroll requests should be reviewed for proper authorization and allowability of proposed expenditures prior to processing Departments should check for allowability of expenditures during the BAR reconciliation process Follow up!  Make the necessary cost transfers or obtain documentation and approval  
 
 
 
 

DOCUMENTATION 

Costs must be specified in the proposed budget and the exceptional or unlike circumstances requiring the direct charging are justified in the proposal When rebudgeting occurs, obtain documentation from the PI that explains the unlike or exceptional circumstances for direct charging the costs.  Explanation must be maintained in the department grant file  
 
 
 
 

MONITORING 

Management should ensure that controls in place are working as planned Review of controls should be  be done on a regular basis Examples of monitoring controls: Review the exception report from GCA Review sample BSRs or download data from FAS to analyze expenditures  
 
 
 
 

MONITORING (CONT)  

Follow-up when unusual pattern is noted Review a sampling of transactions for adherence to controls such as proper documentation, authorization, etc. Periodic meetings with faculty and staff to communicate policy and to discuss concerns.  Document and retain meeting minutes  
 
 
 
 

BEST PRACTICES 

Departmental Examples  
Recommendations  
Documents for Budget/Grant  
 
 
 
 

DEPARTMENTAL EXAMPLES 

Binder of Fiscal Procedures

Org Chart of Business Office  
Org Chart & Practices of Large Programs  
Procedures for each Fiscal Position  
 
 
 
 

RECOMMENDATIONS 

New Budget Memo  
Allowable Charges, Unlike Circumstances  
Signature Authority Form  
File Review - Forms, Signatures  
 
 
 
 

Documents for Budget Files 

Modular Grant Budgets  
Maximum to be covered by department  
Supply Sharing between Projects  
 
 
 
 

CAS QUIZ/ QUESTIONS AND ANSWERS 

Review of Examples on CAS Quiz Handout Question and Answer period  

IN 1996, CAS TRAINING WAS PROVIDED TO CAMPUS COVERING WHAT CAS IS AND WHAT IMPLICATIONS IT WOULD HAVE ON THE UW.  PLANS FOR FOLLOW-UP SESSIONS WERE MENTIONED AND THIS IS ONE OF THE FOLLOW-UP TRAINING SESSIONS WHICH RESULTED FROM AUDIT FINDINGS. 

UW AUDIT RISK BASED ON SUMMARY OF AUDIT FINDINGS FROM 8 DEPARTMENTS REPRESENTING 5 COLLEGE/SCHOOLS-MEDICINE, ARTS AND SCIENCES, ENGINEERING, NURSING AND PUBLIC HEALTH AND COMMUNITY MEDICINE

 

ALONG WITH THESE STANDARDS, A-21 REQUIRES MAJOR RESEARCH UNIVERSITIES TO DISCLOSE OR DESCRIBE THEIR ACCOUNTING PRACTICES.  

THIS 00ISCLOSURE STATEMENT00 OR DS-2 IS REVIEWED AND APPROVED BY OUR COGNIZANT AGENCY, THE DEPARTMENT OF HEALTH AND HUMAN SERVICES (DHHS), TO VERIFY THAT OUR ACCOUNTING PRACTICES COMPLY WITH THE COST ACCOUNTING STANDARDS 

DISCLOSURE STATEMENT WAS APPROVED IN 11/99 

 

OFFICE SUPPLIES EXCEPT FOR OFF-CAMPUS RESEARCH (REFER TO APPENDIX B FROM GIM 23) 

 

ADMINISTRATIVE and Clerical SALARIES

ROUTINE ADMINISTRATIVE SUPPORT SHOULD BE CHARGED INDIRECTLY 

OFFICE SUPPLIES,  ON-CAMPUS

A 00ASE00LEVEL OF OFFICE SUPPLIES MUST BE PROVIDED BY THE DEPARTMENT

EACH DEPARTMENT DETERMINES THE 00ASE00LEVEL THEY MUST PROVIDE

OFFICE SUPPLIES CAN BE DIRECTLY CHARGED TO OFF-CAMPUS SPONSORED PROGRAMS

BASIC TELEPHONE, ON-CAMPUS

BASIC TELEPHONE INSTALLATION AND LINE CHARGES SHOULD BE CHARGED INDIRECTLY

INSTALLATION AND LINE CHARGES CAN BE DIRECTLY CHARGED TO OFF-CAMPUS PROGRAMS

LONG DISTANCE TELEPHONE CHARGES CAN BE DIRECTLY CHARGED TO SPONSORED PROGRAMS

CELL PHONES AND PAGERS MUST BE INDIRECTLY CHARGED UNLESS SPECIFICALLY AND SOLELY RELATED TO THE SPONSORED AWARD

MEMBERSHIPS

MUST BE CHARGED INDIRECTLY, UNLESS THEY00E:

SPECIFICALLY RELATED TO SPONSORED WOR AND LOWERS COST OF CONFERENCE SPECIFICALLY RELATED OR     PROVIDES A JOURNAL SPECIFICALLY RELATED

JOURNALS AND SUBSCRIPTIONS

MUST BE INDIRECTLY CHARGED, UNLESS  SPECIFICALLY AND SOLELY RELATED TO THE SPONSORED AWARD 
 
 

 

00NLIKE CIRCUMSTANCES00 MEANS THE CIRCUMSTANCES RELATED TO A PARTICULAR PROJECT ARE CLEARLY DIFFERENT FROM THE NORMAL OPERATIONS 

UNLIKE CIRCUMSTANCES EXIST WHEN:

1) A LEVEL OF SERVICES OR ITEMS ABOVE THE NORMAL LEVEL IS REQUIRED BY THE SPONSORED PROJECT (EXAMPLE #1)

 

2) TECHNICAL EXPERTISE IS REQUIRED BY THE SPONSORED AGREEMENT THAT OTHERWISE IS NOT NEEDED OR AVAILABLE IN THE DEPT (EXAMPLE #2) 

 

OTHER EXAMPLES:

- PROJECTS WHERE THE PRINCIPAL FOCUS IS PREPARATION AND PRODUCTION OF MANUALS AND LARGE REPORTS, BOOKS, ETC. 

- PROJECTS REQUIRING PROJECT-SPECIFIC DATABASE MANAGEMENT, INDIVIDUAL GRAPHICS OR MANUSCRIPT PREPARATION,ETC.

 

NOTE - LONG DISTANCE CHARGES ARE ALWAYS ALLOWABLE DIRECT CHARGES, PROVIDED THE CALLS CAN BE DIRECTLY ASSIGNED TO A SPECIFIC PROJECT, EITHER THROUGH THE USE OF AUTHORIZATION CODES OR AFTER THE FACT RECHARGING BY THE DEPARTMENT

 

IF A COST BENEFITS 2 OR MORE PROJECTS OR ACTIVITIES IN PROPORTIONS THAT CANNOT BE DETERMINED BECAUSE OF THE INTERRELATIONSHIP OF THE WORK INVOLVED, THE COSTS CAN BE ALLOCATED TO PROJECTS ON A REASONABLE BASIS. 

PROPORTIONAL BENEFIT RATE:

COST IS ALLOCATED ACCORDING TO THE PROPORTION OF BENEFIT PROVIDED TO EACH PROJECT, I.E. LAB SUPPLIES ALLOCATED BETWEEN TWO GRANTS BASED ON QUANTITY USED (OR PLANNED TO BE  USED) ON EACH GRANT

EXAMPLE:  10 BOXES TEST TUBES, 6 TO 1 PROJECT, 4 TO ANOTHER - WOULD BE 60%/40% ALLOCATION

INTERRELATIONSHIP RULE

USE WHEN ITS NOT POSSIBLE TO DETERMINE THE PROPORTIONAL BENEFIT. COST IS DISTRIBUTED BASED ON ANY REASONABLE BASIS, I.E. COST OF LAB SUPPLIES IS ALLOCATED BASED ON ALLOCATION OF EMPLOYEE SALARIES TO EACH GRANT

EXAMPLE:  70% OF SALARIES FOR THE PROJECT ARE ON BUDGET A AND 30% ON BUDGET B; SUPPLIES COULD BE DISTRIBUTED WITH THE SAME PERCENTAGES

 

REBUDGETING MEANS PI CAN INCUR ALLOWABLE EXPENDITURES THAT WERE NOT INCLUDED IN THE ORIGINAL PROPOSAL PROVIDED THE TOTAL AMOUNT AWARDED IS NOT EXCEEDED. 

EXAMPLE:  IF TRAVEL IS FUNDED BUT LATER ON IN THE PROJECT TRAVEL IS NO LONGER NEEDED, PI CAN USE FUNDING FOR OTHER ALLOWABLE ITEMS SUCH AS SUPPLIES. 

ONLY 3 SPONSORS AT THIS TIME ALLOW REBUDGETING AUTHORITY ON GRANTS FOR EXPENDITURES NORMALLY CONSIDERED TO BE INDIRECT - NIH, NSF AND ONR BUT WRITTEN JUSTIFICATION IS STILL REQUIRED.  ZENAIDA WILL COVER MORE ON THIS LATER.

 

TO DETERMINE WHETHER THE SYSTEMS OF INTERNAL CONTROLS ARE SUFFICIENT TO ENSURE COMPLIANCE WITH FEDERAL REGULATIONS AND UNIVERSITY POLICES 

INTERNAL AUDIT SPECIFICALLY REVIEWED CONTROLS IN EIGHT DEPARTMENTS TO ENSURE COMPLIANCE WITH REGULATIONS AND POLICIES REGARDING THE CONSISTENT TREATMENT OF COSTS INCURRED FOR THE SAME PURPOSE AND IN LIKE CIRCUMSTANCES (EITHER AS DIRECT OR INDIRECT COSTS 

AUDIT OBJECTIVE WAS SET AFTER CONSULTATION WITH THE FORMER CAS COMMITTEE.  COMMITTEE FELT THE HIGHEST RISK IS COMPLIANCE WITH THE STANDARD ON CONSISTENT TREATMENT OF COSTS. 

AUDIT EMPHASIS IS ON REVIEWING CONTROLS AND NOT LOOKING FOR UNALLOWABLES.  THE TESTING WE DID IS TO DETERMINE WHETHER CONTROLS ARE WORKING. 
 
 

 

FOR TESTING, IA SELECTED SAMPLES FROM A COMBINATION OF DATA OBTAINED FROM  AN ERGO DOWNLOAD FROM GCA AND A FAST DOWNLOAD FROM IA. 

BE AWARE THAT IT IS VERY EASY FOR AUDITOR TO EXTRACT DATA ON COSTS THAT SHOULD NORMALLY BY CHARGED AS INDIRECT.

 

DIRECTLY CHARGING COSTS THAT ARE NORMALLY DIRECT IS NOT NECESSARILY WRONG IF THERE IS AN EXCEPTIONAL AND UNLIKE CIRCUMSTANCE.  HOWEVER, UNIVERSITY POLICY STATES THAT CERTAIN REQUIREMENTS MUST BE FOLLOWED BEFORE THESE TYPES OF COSTS MAY BE DIRECTLY CHARGED.  IA FOUND THAT THESE REQUIREMENTS WERE NOT BEING FOLLOWED.  THUS, THERE SEEMS TO BE MISSING CONTROL OR CONTROLS TO ENSURE COMPLIANCE WITH THE POLICY. 

QUESTIONS NEED TO BE ASKED:  WHO IN THE DEPARTMENT/UNITS IS SUPPOSED TO REVIEW THE PROPOSALS?  DO THESE INDIVIDUALS KNOW WHAT TO LOOK FOR? DO THEY KNOW WHAT IS CONSIDERED 00XCEPTIONAL AND UNLIKE CIRCUMSTANCES00 HAVE WE SUFFICIENTLY COMMUNICATED THE REQUIREMENTS TO OUR FACULTY? 

AFTER FURTHER REVIEW WE FOUND SOME COSTS WERE ALLOWABLE AND SOME WERE NOT.  FOR THOSE THAT WERE QUESTIONABLE OR UNALLOWABLE, DEPARTMENTS EITHER REMOVED OR AGREED TO REMOVE UNALLOWABLES FROM THE BUDGETS. 
 

 

RISKS:

UNIVERSITY POLICY REQUIRES DEPARTMENTS TO INCLUDE COSTS IN THE PROPOSED BUDGET AND TO HAVE A JUSTIFICATION.  THE UW POLICY IS INCLUDED IN THE DISCLOSURE STATEMENT THAT WAS FILED WITH THE FEDERAL GOVERNMENT. OMB CIRCULAR A-21 STATES THAT EDUCATIONAL INSTITUTIONS ARE RESPONSIBLE FOR COMPLYING WITH DISCLOSED ACCOUNTING PRACTICES.  NON-COMPLIANCE WITH OUR INTERNAL POLICIES MAY BE INTERPRETED AS A VIOLATION OF THE FEDERAL REGULATIONS. 

IF AUDITORS SEE THAT POLICIES ARE NOT FOLLOWED, THEY WILL DIG SOME MORE.  THIS HAPPENED RECENTLY IN A DEPARTMENT WHICH RESULTED IN AN ADJUSTMENT THAT IS NOT ABOUT THE CONSISTENT TREATMENT OF COSTS, I.E. % OF EFFORT. 

EMPHASIZE AGAIN THAT APPROVAL OF THE PROPOSAL BY THE SPONSOR DOES NOT AUTOMATICALLY MEAN ALL COSTS WOULD BE ALLOWED IN AN AUDIT.  THE AUDITORS, NOT THE PROGRAM PEOPLE WILL ULTIMATELY DETERMINE ALLOWABILITY.  PROGRAM  PEOPLE DO NOT NECESSARILY KNOW THE ACCOUNTING PRACTICES THAT THE UNIVERSITY HAS DISCLOSED. 
 
 
 

 

INDIVIDUALS WHO ARE RESPONSIBLE FOR PROCESSING, RECONCILING AND APPROVING SHOULD KNOW WHICH COST CATEGORIES ARE ALLOWED. 

FOR THOSE BUDGETS THAT HAVE AN EXCEPTIONAL OR UNLIKE CIRCUMSTANCE, IT MIGHT BE GOOD TO HAVE A MATRIX THAT LISTS WHICH COSTS CAN BE DIRECTLY CHARGED. 

NEED TO DO A RISK MANAGEMENT.  DO WE ADJUST ALL THAT APPEARS UNALLOWABLE?  YOU CAN LOOK AT MATERIALITY.  IS THIS A ONE TIME CASE OR IS THERE A PATTERN?

 

DOCUMENTATION REQUIREMENTS ARE THE SAME FOR BASIC GRANTS AND FOR MAJOR PROJECTS.  OUR POLICY DOES NOT DISCRIMINATE.  

SOME DEPARTMENTS NOTE THE EXCEPTIONAL CIRCUMSTANCE ON THE PURCHASE REQUISITION.  SOME PLACE THE EXPLANATION ON THE INVOICE OR ATTACH THE EXPLANATION TO THE INVOICE. 

RECOMMEND KEEPING THE EXPLANATION IN THE GRANT FILE SO YOU ONLY HAVE TO DO IT ONCE.  ALSO, THERE MAY BE A PROBLEM WITH RECORDS RETENTION 

NOTE THAT EXCEPTIONAL NEEDS MAY ONLY BE FOR CERTAIN TYPES OF SUPPLIES AND NOT ALL OFFICE SUPPLIES.  FOR EXAMPLE, A GRANT MAY NEED ENVELOPES FOR MAILING BUT DEPARTMENT STILL NEED TO PROVIDE BASIC OFFICE SUPPLIES.  DOCUMENTATION SHOULD BE SPECIFIC.

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