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Guidelines on the Use of Budget and Expense Object Codes: Federal and Non-federal Awards and Non-sponsored Funds
One of the main purposes of the new chart of accounts is to enable the University and its local units to easily budget, capture, sort, and report financial data in the appropriate categories, both for internal financial management and to ensure compliance in an increasingly complex and demanding regulatory environment. Choices made between general and detailed expense object codes have a major impact on the ability of the University and local units to achieve the full benefits inherent in the new chart of accounts.
Federal Awards
Direct Costs
For Direct Costs, use the same object codes to budget and transact at the level of detail required by the sponsor. While the reporting requirements and local tracking needs might not always call for the expense coding at the detail level, OMB A-21 and the Cost Accounting Standards require costs to be accumulated and reported at the same level proposed in the budget. For example, if "scientific supplies" are listed in the grant proposal, then this expense code must be used to charge these supplies. "General Supplies" would not provide sufficient detail and would place us out of compliance. Thereby, to satisfy CAS requirements, the above is an example of one situation where we are requesting local units to use the level of detail reflected in the proposal.
Indirect Costs
When charging costs that are typically "indirect" directly to federal awards, use object codes that clarify allocability/allowability. By way of example, " long distance calls" are usually allowed as a direct cost. "Local calls" are typically not allowable unless the nature of the award is one where an inordinate amount of local calls is required (e.g., a survey grant). In cases like these where greater detail will clarify compliance concerns, we request that lower level expense object codes to be used.
Subcontracts
For Subcontracts, use the same object codes to budget and transact. In the past, we have only had one class to reflect all types of subcontract expenses. In the new object code list, we have available to us various codes reflecting the type of subcontract expense: subcontract salaries, subcontract equipment, etc. As there is increasing external audit pressure on us for subrecipient monitoring, one way of satisfying this requirement is to require a level of detail in the way subcontract expenses are coded. In addition to providing assurance for external purposes, using greater level of detail in this case will provide us with additional comfort that subcontractors' billing is appropriate and allowable.
Non-federal Awards
For non federal awards, you may use the general, higher level expense object code unless sponsor guidelines stipulate otherwise.
New object codes for charging project-related overhead costs to non-federal sponsors
New expense object codes, seen below, have been created to enable Tubs to charge non-federal sponsors for defined line items that are project-related indirect costs. The F&A fees may be charged as lump-sum costs for defined line items either in lieu of or in addition to recovering costs solely through F&A rates.
The "F&A Fee" expense object codes will not assess overhead, will be used to debit only NE or NG funds (200000-299999) and credit only non-sponsored funds. The F&A fee codes should be used only when the NE/NG funded activity has a F&A rate that is lower than the Tub's federally-negotiated rate and only when budgeted in an agreement that has been approved by the non-federal sponsor. The five F&A Fee expense object codes include one for general costs and one each for facilities, administration, library and University Assessment costs. Tubs may estimate project-related overhead costs per category, as applicable to the project, and submit budget proposals to non-federal sponsors including F&A fees per line item.
For further information or questions about the use of the F&A Fee object codes, contact: judy_ryan@harvard.edu or 495-1520.
Object codes for charging non-federal overhead cost recovery by defined line items
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Non Sponsored Funds
For nonsponsored funds, you should feel free to use the general, higher level expense object codes, unless you have local tracking needs which may be facilitated by using codes with a finer level of detail.
Interdepartment and Intradepartment Charges
ABLE On-line Reference: Internal TransactionsSummary
In summary, for federal awards where compliance concerns are apparent (CAS, administrative costs charged directly to federal awards, subcontract expenses, among others) we are requesting that a lower level of detail to be used than the general broad category of expense type.
If there are any questions about which object code to use for a sponsored transaction, please call your OSP Financial Services Team Leader.
