Post Award - Sponsored Compliance

Expenditure Approval

The PI(s) and University of Tulsa agree to abide by the sponsor terms and conditions upon acceptance of the award. It is the responsibility of ORSP administration to monitor the cost activities of an award in accordance with the policies of The University of Tulsa as well as the regulations of the sponsor to ensure compliance. Costs must pertain to the project activity, be within the allowable performance period, and adequate award funds must be available. Unallowable expenditures become the responsibility of the PI(s) and their department.

Costs applied to a federal award must comply with the OMB Circular A-21 and any additional specific terms attached. Expenses are generally permissible on sponsored agreements, if they are:

Reasonable – A prudent person purchasing this item would have paid this price.

Allowable – Allowable costs and unallowable costs are specified by government regulations (OMB A-21, Section J, see below) and any award restrictions.

Allocable – Expenses can be allocated to the government activity based on benefit derived, cause and effect, or other equitable relationship. Allowable – Allowable as specified by government regulations (OMB A-21, Section J) and award restrictions.

Consistently Treated – Similar expenses charged to other entities by the University must be treated the same in like circumstances as with the government.

In order for expenditures to be charged to a sponsored project account, paperwork must be initiated, in accordance with University Purchasing Policies and Procedures, by the project director in the form of Purchase Orders, Check Requests, or Travel Reimbursements through the PI(s) designated department. Reimbursements may be submitted by Check Requests or Travel Expense Reports and should be submitted no later than thirty (30) days from the date the expenses occurred. Each expenditure must be reviewed for proper documentation and appropriateness as stated above.


Unallowable Costs (Activities and Objects)*

(When charged against federal agreements or placed in the indirect cost base, refer to

OMB Circular A-21, Section J.  Costs must also comply with university policy (see TU Purchasing Policies)







(J.1) Advertising (some types allowed)

(J.1) Some Advertising and Public Relations


(J.3) Alcoholic Beverages

(J.4) General Public Relations & Alumni Activities


(J.6) Bad Debts

(J.8) Commencement & Convocation


(J.11) Contingency Reserves (except as noted in (J.11))

(J.13) Prosecuting Claims Against the Federal Government


(J.15) Cash Donations to Other Parties (such



as donations to other universities)

(J.15a) Contributions made by the University (except as noted further in (J.15))


(J.17) Entertainment

(J.20) Organized Fund Raising


(J.19) Fines and Penalties

(J.22) Managing Investments Solely to Enhance Income


(J.21) Insurance (some types allowed)

(J.28) Lobbying


(J.22) Interest (some types allowed)

(J.48) Student Activities (Student Services)


(J.23) Housing and personal living expenses for/of institutions or officers



(J.29) Losses

*Note: The number preceding each item is the corresponding number under Section J


(J.37) Certain Recruitment Costs

of OMB Circular A-21.


(J.43) "Golden Parachute" Severance Payments





(J.48) Certain Travel Costs (e.g. first class)



(J.53c) First Class Travel (see J.53 for exceptions)

Food and Entertainment are unallowable against most sponsored projects without prior written approval from the agency.  Food and entertainment costs for Public Functions related to a project should be clearly stated and budgeted at the time of proposal submission.  Agency approval should be provided to the Office of research for audit documentation.  (See J.15)

General Purpose Equipment and Supplies - (Office supplies and equipment, e.g., computers, file cabinets) are unallowable against most sponsored projects without prior approval from the agency.

Overtime (Extra Compensation Above Base Salary) - Extra compensation payments against most sponsored projects are unallowable without prior written approval from the agency.  Any overtime accumulated and submitted for payment, should not be automatically charged to sponsored projects and must have prior approval from the Office of Research and Sponsored Programs.  (See J.8)

Communications Costs - Costs incurred for telephone services (excluding general line service costs unless solely dedicated to a project) local, long distance, telegrams, postage, messenger, electronic or computer transmitted services are allowable.  PAC codes are discouraged against sponsored agreements due to automatic processing which results in billings after projects end.  The department may bill for costs by using a Cost Transfer.  Automatic billings placed after a project ends will be charged to the department.  (See J.7).