Computing Devices Funded by University of Arkansas Sponsored Programs
This document is intended to serve as formal guidance for University of Arkansas regarding the purchase of computing devices with funds from sponsored programs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the University of Arkansas Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
Computing devices are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR 200.20 and 2 CFR 200.94 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.
University of Arkansas considers computing devices to incorporate computers and electronic devices costing less than $5,000 per unit, including but not limited to: desktop computers and laptop computers, tablets, iPads, smart phones, e-readers, printers, and external hard drives. See the Procedural Statement for Equipment for computing devices costing more than $5,000 per unit.
Due to the fact that these items are considered sensitive property by the U.S. General Services Administration 41 CFR 102-35.20, additional documentation is required to differentiate them from other general supplies.
The Uniform Guidance states that computing devices are allowable as direct costs but do not need to be solely dedicated to a program, indicating that some non-program use is acceptable, although the predominant use of the computing device should be on the program. Costs of computing devices not related to the sponsored program must be allocated to an unrestricted source. 2 CFR 200.453(c) also states that “In the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal award”.
Principal Investigators shall explain how computing devices fit the criteria of being essential and allocable to the performance of their Federal award because of the following reasons:
- Computing devices have the capability for providing non-program benefit, and
- Computing devices are considered sensitive property by the U.S. General Services Administration and, as such, require special control and accountability.
It is important to review each award’s terms and conditions, as written sponsor guidelines may prohibit the purchase of computing devices on certain sponsored awards.
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-funded and other activities of the university. Therefore, University of Arkansas Cost Principles Policy, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for purchasing computing devices are similar for non-Federal sponsored programs but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of computing devices should be provided in order to explain why these are essential to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.
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.
After an Award is Funded
Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted computing device is required after an award is funded, the department can work directly with Research Accounting if questions arise about what is required to ensure that this purchase is properly documented. The purpose and benefit of the device to the specific program should be described in the justification and retained by the department for future reference should the expenditure be questioned at a later date. The justification may also be stored in an approved university procurement system with purchase documents.
If the documentation was not obtained at time of purchase, Research Accounting may ask for the documentation at closeout or during a periodic review of expenditures.