I. Procedural Statement
This document is intended to serve as formal guidance for ֱ Boulder regarding the use of funds from sponsored projects for relocation costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored research. Procedural statements support the ֱ Boulder Cost Principles Policy by providing definitions and processes for meeting those standards.
II. Defintions
Relocation costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, as:
Relocation costs are costs incident to the permanent change of duty assignment (for an indefinite period or for a stated period of not less than 12 months) of an existing employee, or upon recruitment of a new employee.
Eligible employees are current employees with a 100% full-time equivalent appointment or new hires who will be in a 100% full-time equivalent appointment.
III. Procedures
A. Federal Awards
Under the guidelines imposed by the Uniform Guidance, relocation expenses may be considered allowable direct charges under certain circumstances, subject to limitations.
ֱ Boulder considers relocation costs for new hires or existing employees to be allowable on sponsored projects if the position is essential and allocable to the performance of the award. Eligibility is limited to research faculty, research associates, and post docs.
A position is considered essential under the following conditions:
Relocation costs are allowable on sponsored projects, provided that allthe following conditions apply, and are subject to limitations outlined below:
Limitations on Allowability
- For new hires, the relocation costs to be covered should be listed in the offerletter. If the cost is significantly higher than what the department historicallyhas provided, the (section II.E of APS 4015 - Propriety of Expenses)should be used, and additional justificationprovided. Allowable relocation costs for current employees or new hires arelimited to the items listed below:
- If the newly hired employee resigns within 12 months after hire for reasonswithin his or her control, all associated relocation costs must be removedfrom the federal award and charged to a departmental account. If theemployee is terminated by the unit within 12 months, relocation costs can stillbe charged to the sponsored project.
- If an existing employee, or a new hire, is being moved to an overseaslocation, and both of the following conditions apply, the cost will beconsidered a travel cost in accordance with , anddepartments should follow the university's travel policy (link available inSection D.)
Unallowable Costs
B. Non-Federal Awards
Section of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, ֱ Boulder’s Cost Principles Policy, and related procedural statements, are also applicable to non-federal awards. The basic criteria for relocation costs are similar for non-federal sponsored projects, 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 relocation costs should be provided in order to explain why these are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project being charged, even when the non-federal sponsor may follow more flexible spending guidelines.
C. Process
At Proposal
The relocation cost should be identified in the proposal budget justification if possible, and justified as to why it is necessary 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 cost. Written justification and/or 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 relocation cost is required after an award is funded, the department can work directly with the assigned grant accountant to ensure that this cost is properly documented (including any eligible charges paid by a new employee that would be reimbursed by ֱ Boulder with sponsored project funds). The documentation must be retained by the department and available upon request. The purpose and benefit of charging the relocation costs to the specific project should be fully described in the justification, and retained for future reference, should the expenditure be questioned at a later date.