Purchasing Computers on Sponsored Projects

Recent changes in Federal regulations as outlined in Uniform Guidance have allowed awardees more flexibility to charge computers to sponsored projects as direct costs. As a result of these changes, the Office of Sponsored Research (OSR) no longer requires prior approval to purchase a computer to be used on a sponsored project and has discontinued the use of the Application to Purchase Computers with Sponsored Research Funds form.

The flexibility and discontinuation of the form does not remove our responsibility to use funds wisely and be compliant with an award’s terms and conditions. If you desire to purchase a computer with sponsored project funds, please keep these points in mind:

• The expense should be included in your proposal budget and budget justification when possible.
• Verify that the terms and conditions of your award allow for the purchase before making it.
• Make sure the computing item you wish to purchase is essential to the project and be able to answer these types of questions if asked: What benefit to the project does the purchase provide? What activities will be conducted with the purchase? What is the impact on the project if the item is not purchased?
• Make sure the cost of the item is reasonable and ensure you can explain why it is reasonable to you. Would a prudent person consider it a reasonable purchase? Would you pay this price if it was a personal purchase?
• Make sure the cost of the item you wish to purchase is properly allocated to the project. For example, if a purchase will be used by two projects 50% of the time, its cost should be split 50/50 between the two projects.
• Make sure the project does not have reasonable access to already existing resources that may achieve the same purpose as a new purchase. Computing devices are not to be purchased for reasons of convenience, preference, or to spend down remaining funds.
• If the cost is greater than $5,000, the item is considered capital equipment under Federal regulations and Federal rules apply.

To learn more about the Federal regulations governing equipment, please refer to the following Uniform Guidance sections: 2 CFR 200.33, 2 CFR 200.48, 2 CFR 200.89, 2 CFR 200.439, and 2 CFR 200.453(c).

If the OSR Post-Audit Team does not find a form on file when auditing a project, depending on the date of the purchase in relation to this announcement, you may be contacted to provide one.

If you have any questions with regards to computer purchases on a sponsored project or this announcement, please reach out to your OSR Sponsored Projects Specialist.