University Policy 5035
Effective Date
May 29, 2026
Last Revision Date
N/A
Responsible Party
Vice President for Research and Economic Development, (208) 426-5372
Office of Sponsored Programs, (208) 426-4420
Scope and Audience
This policy applies to any compensation provided by any Sponsored Project including projects and funding sources identified as Committed Cost Share. All Principal Investigators (“PIs”) and cognizant college/departmental/unit administrators (“Administrators”) at Boise State University (“University”) within all colleges, schools, units, divisions, centers, institutes and University-wide initiatives must comply with this policy.
Additional Authority
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200) (the “Uniform Guidance”)
1. Policy Purpose
The University’s system of internal controls help ensure that compensation costs are charged in accordance with applicable policies governing the proper authorization of expenditures. Central, but not exclusive among these internal controls, is the federal guidance for the after-the-fact review of interim charges that are based on budget estimates. In accordance with 2 CFR § 200.430(g)(1)(vii)(C), this policy addresses the after-the-fact review requirements so that the final amount charged to the federal award is accurate.
2. Policy Statement
After-the-fact verification of compensation charged to Sponsored Projects is required to ensure the University is compliant with regulations and award terms and conditions.
3. Definitions
Allocable: A cost is allocable to a Sponsored Project if it: (1) is incurred specifically to advance the work under the Sponsored Project; (2) benefits both the Sponsored Project and other University work in proportions that can be approximated through the use of reasonable methods; or (3) is necessary to the overall University operation and, in light of the Uniform Guidance, is deemed to be assignable in part to the Sponsored Project. See, e.g., 2 CFR § 200.405.
Allowable: A cost is allowable if the cost: (1) is Necessary and Reasonable (definitions follow) and permitted to be charged under the terms and conditions of the Sponsored Project; (2) satisfies Cost Allowability requirements, with an emphasis on 2 CFR § 200.430; and (3) is treated consistently, regardless of funding source, through the application of Generally Accepted Accounting Principles appropriate to the circumstances. See, e.g., 2 CFR § 200.403.
Committed Cost Share: The portion of Sponsored Project costs not borne by the sponsor that has been quantified in the proposal and made as a condition of award. Committed cost share can be mandatory or voluntary committed (see policy 6110).
Institutional Base Salary (IBS): Employee’s contracted University salary assigned for performing Regular Duties for the applicable Base Salary Period (see policy 7195).
Necessary: A cost is necessary if it is integral to supporting the performance of the approved scope of work.
Principal Investigator: The individual responsible for the technical and financial performance of a Sponsored Project (see policy 5030).
Project Anniversary Date: One calendar year from the start date of the Sponsored Project.
Project Payroll Verification Report: The report distributed to the Principal Investigator,
or designee, of the compensation expenditures charged to a Sponsored Project. The purpose of the Payroll Verification Report is to confirm that compensation expenditures charged to a Sponsored Project are accurate and reasonable in relation to the work performed by each individual.
Reasonable: A cost is defined as Reasonable if it does not exceed the amount a prudent person would incur under similar circumstances at the time the decision to incur the cost was made. See, e.g., 2 CFR § 200.404.
Sponsored Project: A grant, contract, cooperative agreement, sub grant, subcontract, consortium agreement, purchase order, or memorandum of understanding that formalizes the transfer of money or property from a sponsor in exchange for specified activities (e.g., research and development, instruction, public services etc.), and may require specific deliverables such as detailed financial and/or technical reporting by the recipient. Performance is usually to be accomplished within a specified time frame, with payment subject to revocation. It may include provisions related to intellectual property and publication rights. The University’s Office of Sponsored Programs (OSP) in the Division of Research and Economic and Development is responsible for accepting and administering sponsored projects.
Voluntary Uncommitted Cost Share: Cost sharing specifically pledged by the University on a voluntary basis which is not required by the sponsor as a condition of receiving an award. These costs are not quantified in the proposal or award and do not need to be tracked or reported.
4. Compensation on Sponsored Projects
All compensation costs charged to a Sponsored Project must be Reasonable for the work performed, Allowable per sponsor and University policy, and Allocable to the Sponsored Project. For federally funded projects, compensation charges must be based on a rate not in excess of an individual’s IBS, adequately documented in accordance with 2 CFR § 200.430, and be in accordance with applicable governing authoritative guidance, including sponsor requirements and University policy.
In accordance with 2 CFR § 200.430(g)(1)(ix), “It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. Therefore, a precise assessment of factors contributing to costs is not required when [Institutions of Higher Education] record salaries and wages charged to Federal awards.”
In accordance with the University’s procedure for after-the-fact review of compensation charges to Sponsored Projects, the after-the-fact review of Project Payroll Verification Reports are performed by the Principal Investigator or the Principal Investigator’s designee with appropriate project knowledge. Project Payroll Verification Reports must be reviewed periodically in accordance with OSP procedures to verify that the compensation of individuals charged to or reported as Committed Cost Share towards a Sponsored Project reasonably reflects the work performed.
Responsibilities of the Principal Investigator or designee, department administrative staff, and OSP are set forth in the procedure for the review of compensation charges to Sponsored Projects.
5. Exclusions
a. Compensation charged to an institutional source is not covered under this policy, except for compensation used in support of Committed Cost Share.
b. The accounting of Voluntary Uncommitted Cost Share for a specific project is not covered under this policy.
6. Related Information
Research OSP Compensation Compliance
Revision History
May 29, 2026