Isr Draft Policy Statement

ISR POLICY STATEMENT – REVISED October 2017 Non-Capital Computer Equipment and Computing Supplies

Introduction CMU’s Sponsored Projects Accounting Office (SPA) has announced a more conservative interpretation of allowable expenditures on Federal grants under A-21. SPA has ruled that non-capital computer equipment and computing supplies may not be charged to grants from Federal sources even if the approved budget specifically contains these line items. All computing equipment priced less than $5k is deemed “non-capital.” It should be note that items that are truly “technical supplies” (i.e. equipment and consumables that are specific to a particular project such as a mobile communications device purchased for a specific Federally- funded research project on mobile commerce or a set of specialized image capture cameras used to build a prototype under another Federal award) will remain allowable if they are classified as such, included in the budget, and properly documented and justified.

Additionally, ISR will be liable, at the departmental level, for covering any costs charged to Federal awards prior to July 1, 2009 that are later deemed to be unallowable. We intend to argue that, in many cases, these charges should be allowed, but we do not anticipate a high level of success.

As a consequence, starting July 1, 2009, we will need to find other ways to pay for the ‘non-allowable’ charges noted above. Also, new budgets submitted to Federal sponsors should not include items in these categories; a line item for technical supplies may be included but will need to be heavily justified and tracked explicitly – caution should be exercised in this area as any charges deemed to be unallowable in this category by SPA after July 1 will need to be covered from faculty-controlled funding sources (discretionary, FRAS, etc.) when the award is closed out.

Impact The good news is that the overall total of charges in these categories is relatively low. In FY08, for example, ISR charged approximately $48k in non-capital equipment (primarily laptops and desktops) and $15k in computing supplies to Federal funding sources; in FY09 YTD, the respective numbers are $38k and $1.3k. Certainly, it will not be particularly pleasant to absorb these costs, but it will not be the end of the financial world either.

Need Given this SPA ruling, ISR needs to develop a way to provide non-capital computer equipment to its students, staff, and those members of the faculty who have been traditionally dependent upon Federal funding sources for this equipment. ISR also needs to develop a way to assist in covering expenses for computing supplies that have historically been charged this way as well, for those faculty and research centers that have come to rely upon it.

Policy for Non-Capital Computer Equipment ISR will provide each new PhD student, staff member, and faculty member with non-capital computer equipment of their/their advisor’s/supervisor’s choice upon joining the department according to the following schedule:

 PhD Students – up to $3,000  Administrative Staff – up to $3,000  Technical Staff and Post-Doctoral Associates – up to $3,500  Faculty – up to $5,000

Equipment costs will be assigned to the appropriate administrative unit within the department for PhD students, faculty, and administrative staff (e.g., COS, eBusiness, ExecEd, etc.), and to the department centrally for technical staff. Individual administrative units may impose higher/lower equipment budgets than those specified above, and may opt out of purchasing new equipment for a new staff member (for example, if the equipment used by the new hire’s predecessor is less than three years old).

Equipment will be replaced at the department’s expense on a three-year cycle, subject to an evaluation of business need and availability of funds. Faculty may refresh and enhance their machines and the machines of their staff at a more rapid pace, or acquire secondary machines, accessories, etc., through alternate, allowable funding sources such as industrial and discretionary funds.

Equipment should be procured through the appropriate channels. Machines purchased with departmental funds for students and staff members will be placed on full support with SCS Computing Facilities (network, hardware/software, and back-up). Machines purchased with departmental funds for members of the faculty will be placed on support with SCS Computing Facilities at a level selected by the faculty member. To ensure minimal downtime in the event of system failure, the department strongly encourages faculty members to select full support for their machines. Note that software support is required on all faculty machines purchased with departmental funds to comply with software site-licensing requirements. Faculty members who opt out of SCS support do so with an understanding 1) that this may severely limit or even eliminate the ability of the SCS Help Desk and the ISR ITS team to assist with software and hardware failures, and 2) that they will be responsible for the upkeep and maintenance of their machines and will need to coordinate directly with the manufacturer for in-warranty repairs. All support charges will be applied pursuant to the standard practice of the department (based on labor distribution). Machines purchased with non- departmental funds do not need to be centrally supported. Exceptions to this requirement may be granted by the department head.

Policy Statement: Computing Supplies Computing supply expenses charged to Federal funding sources have historically been quite low (totally less than $1k per month over the past two years). This indicates that most computing supplies have either been allocated to academic programs or charged against other funding sources as has been appropriate. Nevertheless, we recognize that the new A-21 interpretation will result in some faculty members and centers no longer having access to funds they may have been expecting.

As such, we will provide annual support to research groups, via a dedicated account, to impacted faculty members who draw substantially on research funds (i.e., faculty members outside of the teaching track). The amount is determined by the size of the faculty member’s research group (the faculty member and administrative support personnel are excluded from the count):

 0 (i.e. faculty + admin only) – $100  1 to 5 – $200  6 to 10 – $500  11 to 15 – $1,250  16 to 24 – $2,000  25 and above – $2,500

These funds will be placed into a FRAS account for each impacted faculty member on or about July 1 of each fiscal year, and the balance communicated to the faculty member by the business office immediately upon funding.