Tracking Non-Reimbursable (Unallowable) Costs for the F&A Rate Proposal
What are Non-reimbursable Costs?
Expenses deemed non-reimbursable by the federal government either as:
- Direct costs on grants or
- Indirect costs included in F&A rates.
Listed in detail in Section J of A-21i, and include such things as:
- Fundraising and lobbying costs
Why do we Track Non-reimbursable Costs?
- We must demonstrate to federal reviewers that the calculations leading to our proposed F&A rate do not include non-reimbursable expenditures.
- “Non-reimbursable” costs are posted primarily to non-research budgets classified in F&A categories.
- MAAi removes reported non-reimbursable costs from the F&A rate proposal.
How Should Non-reimbursable Costs be Tracked?
- Refer to a description of A-21 non-reimbursable costs expenditures:
- Review all state, gift, and RCR budgets for any unallowable activity.
As part of monthly reconciliation process, highlight any unallowable activity.
- PCA codes
- MyFD reconciliation comment field
- Existing internal reconciliation processes
What about sponsored budgets and discretionary (64-budgets):
- Expenses on sponsored budgets are assumed allowable.
- Expenses on 64-budgets assumed are non-reimbursable.
Who should review and update budget classifications?
Departmental representatives with first hand knowledge of:
- Nature of expenses, and
- Clear understanding of A-21 non-reimbursable definitions
- Departmental representatives with first hand knowledge of:
When should transactions be reviewed?
- Throughout FY 2013 as part of regular budget review process.
- MAA will follow-up with departments in early fall 2013.
What Documentation is Required?
We recommend you keep back-up:
- For budget cost category review – notes that support your review
- For non-reimbursable expenditures – e.g., notes in the comments field in MyFD (“NRA”)
- Keep back-up in your departmental files
- Keep in mind that the proposal will be reviewed by the HHS negotiators months after you make these determinations.
- What will help you remember what you did?
What Time Period Should be Used?
- The proposal is based on a full fiscal year of costs and activities (FY 2013).
- All non-reimbursable costs recorded during FY 2013 should be tracked and reported to MAA.
- FY 2013 is July 1st, 2012 through June 30th, 2013 (aka, the “FY 2013 F&A Base Year”)
When Should This be Completed?
- Monitor space inventory, cost categories, and non-reimbursable costs throughout the fiscal year and document as changes are needed.
When does MAA need the data?
- Space inventory: December 2012 updated through June 2013
- Budgeti review: May 2013
- Non-reimbursable costs: August 2013