The PI should review the budget ensure costs are allowable and identify any items that may require modifications. Planned expense forms such as Memorandum of Agreements (MOAs), purchase requisitions (PRs), and travel authorizations should be completed before making the expenditure. Forms for award expenditures need the signatures of the PIs and the OGRD POC before being routed to their respective departments for processing. If these documents are prepared electronically, they will be processed electronically using the appropriate approval queues.
The OGRD recommends the PI to keep a copy of all forms, invoices, and documents for reference. Invoices or reimbursements, on average, take 30 days to be paid.
The Washington State Governor, Legislature or Federal Government may issue special regulations restricting expenditures at any time. Awards must comply with these regulations, regardless of the source of funding, or be deemed exempt. The project POC will notify the PI regarding these special conditions as necessary.
Allowable Cost Examples
- communication costs
- operating supplies and materials
- travel, equipment
- and similar costs.
Unallowable Cost Examples
- Alcoholic beverages
- bad debts
- traffic tickets
- alumni activities
- commencement costs
- donations and contributions
- entertainment costs
- and lobbying costs.
Procurement training is provided by the Purchasing Department (see https://sites.ewu.edu/procurement/training/). The PI must generate online purchase requisition forms through Banner and submit invoices for payment when the items are received. If the payment is in the form of a reimbursement, the original receipt(s) must be submitted with the purchase requisition form to the OGRD.
When a department purchasing or procurement card is used to purchase items, route the monthly Transaction Detail report to the OGRD POC for signature.
The MOA form and instructions are located on the Purchasing Department’s forms page at https://sites.ewu.edu/procurement/forms/. The PI is responsible for generating MOAs for personal services provided on an award by a consultant for an amount NOT to exceed $10,000.
MOAs may be used for personal services which exceed the $10,000 threshold provided one or more of the following conditions are met:
- The individual providing the services was identified in the grant or contract proposal and is critical to the successful conduct of the program.
- The services are critical to the instructional mission of the university.
- The services are advertised and a bidding process is used to obtain the contractor.
- The services to be provided are limited in nature and the scope of work does not pose a high risk or potential liability to the university.
The “Contractor Information” section of the MOA (bottom of form) must be signed by the contractor in order for payment to be made. The PI must provide the original MOA to the OGRD for processing at least two weeks prior to the performance of services. Signature authorization on the MOA by the OGRD indicates that sufficient funds are available in the restricted index and the services and associated expenses are allowed and allocable to the grant fund.
The Purchasing Department requires the MOA be received at least seven business days in advance. Purchasing will assign a Banner number to the MOA and a copy of the completed Banner MOA will be e-mailed to the PI.
It is the contractor’s responsibility to prepare and submit the invoice(s). The PI must instruct the contractor to submit an invoice directly to the PI after services have been performed. The contractor may submit their own invoice or use the Contractor Invoice template located athttp://inside.ewu.edu/financialservices/office-of-controller/accounts-payable/AP-Forms.xml.
To ensure paymentwhen services are completethe MOA must have:
- Index number
- Purchase Order (PO) number
- PI signature
- State “Okay to pay”
Refer to the MOA instructions if a check is to be prepared and ready on the date of the performance of the services.
Important things to consider when using an MOA:
- MOAs on which the contractor is paid in a single payment show as an expense on the university's accounting system at the completion of services. Therefore, the funds are not encumbered by the system when the contract is initiated. It is therefore incumbent upon the PI to commit the funds in their own records so funds are not inadvertently spent for other purposes. This is especially crucial if the services are provided over a relatively long period of time.
- An MOA to be paid in progress intervals must be expensed in one fiscal year. If the services are provided across fiscal years, a second MOA must be generated for the second year of services. EWU’s fiscal year ends on June 30 each year.
- In order for the contractor to be reimbursed for expenses other than direct compensation (such as travel, mileage, and meal per diem), the contractor must submit an itemized invoice on letterhead or the PI must complete an A-19 invoice voucher to forward to the OGRD. The A-19 invoice voucher must indicate the MOA contract number, a description of the expenses, and the grant or contract index number. Original receipts must be supplied for expenses (i.e., airline tickets, hotel expenses) which normally require receipts.
The A-19 must be signed by the individual contractor when there will be a reimbursement for expenses such as travel mileage and meal per diem that do not require receipts.
Reimbursement will only be made at the state or funding agency allowed rates for mileage, hotels, etc., regardless of the actual cost.
- Compensation for the performance of services equal to or greater than $600, along with any expenses included in the total contract amount not specifically identified, will be reported to the Internal Revenue Service on a Form 1099 as taxable income.
- Significant expenses, such as airline tickets and lodging may be paid directly on behalf of the contractor using a Purchase Order. The MOA contract number needs to be included on the Purchase Requisition and the expenses need to be listed and identified as being paid by a Purchase Order on the MOA.
- If additional expenses are not included in the total contract amount and are not paid on a Purchase Order, then the PI needs to check that they will be paid in addition to the contract amount on the MOA and identify those expenses and their estimated costs. Expenses incurred that are not identified on the MOA cannot be reimbursed without a receipt regardless of whether or not a receipt is normally required.
- Students may not be paid on MOAs.
When working under an MOA, the contractor is not considered an employee of the university and is, therefore, not covered under Worker’s Compensation.
Regardless of award guidelines, all travel must comply with Washington State approved rates unless federally allowed rates or funding agency rates are less than the state rate. In the case of lower federal rates, the federal rates will apply to federal grants or contracts.
Travel related training is provided by the Travel Accounting Office. Travel authorizations are routed to the POC for approval twice: upon submission prior to travel and when the expense report is submitted after travel. The budget authority, OGRD, Travel Accounting and Accounts Payable all review and approve the travel authorization as it is electronically processed.
International Travel Supported by Federal Funding
The Fly America Act of 1974 requires that U.S. flag air carriers will be used to transport personnel and property when costs are charged directly to a grant or contract. This includes air transportation to, from, between, or within a country other than the U.S. when U.S. flag air carriers are “available” even though:
- comparable or a different kind of service can be provided at less cost by a foreign-flag air carrier, and
- foreign-flag air carrier service is preferred by, or is more convenient for, both the government and the traveler.
If the grant or contract requires international travel, please contact the OGRD for additional information on the requirements of the Fly America Act.
See the university policy for MLR.
Before charging refreshments and other food items to a grant or contract, first verify that the expense is allowable based on the award terms and conditions. Next, identify the specific guidelines the funding agency uses as they may differ from the university’s guidelines. Then, complete a Meals and Light Refreshments Form (MLR).
The PI is responsible for completing a Purchase Requisition and the MLR form prior to an event. Consistent with university policy, a formal agenda, attendance roster or registration list and an additional list of non-registered persons attending the event must be attached and submitted, along with the MLR form approved by the PI, appropriate dean or vice president, to the OGRD for processing.
Initiate an Interdepartmental Purchase Order (IDPO) form when making purchases from university departments. The other department, from which the purchases are made, will complete the IDPO and forward it to the OGRD POC for signature.
The requisitioning department authorizes the “Supplying” department to provide it with the services and merchandise ordered by completing the IDPO with the understanding that the accounting office is authorized to charge and credit the affected department accounts for cost, based on formulae which have been approved by the administration. A notice of completion of services rendered or merchandise delivered will be sent to the requisitioning department in the form of a copy of the invoice then forwarded to the accounting office. Charges will be made in the month the transaction is completed. A PI signature is required to indicate the purchased items were received.
When costs are charged to an index in error, determine the correct index and prepare a journal voucher (JV) entry. If necessary, the POC can assist in generating this form and obtaining the needed support documentation with written PI authorization. Include documentation supporting the expense, like the Detailed Transaction (FGRODTA) report generated by the Banner Finance System showing the posted expense. Make corrections as soon as possible upon the identification of the error.
If the award includes subawardees (subcontractors), the PI is responsible for reviewing all invoices submitted by the subcontractor and determining that all costs are appropriate and allowable, and forwarding to the POC to process for payment. Include the index number, subcontract number, PI signature, date, and state “ok to pay” on the invoice. The PI must review invoices in a timely manner so the university can meet its obligation to pay in a timely manner.
When payments are made to non-university employees, including students, who have participated in a grant or contract program for purposes other than to provide services (i.e.: classroom teacher) an A-19 invoice voucher must be prepared, signed by the PI, and forwarded to the OGRD for processing.
Depending on the circumstances for which an individual receives a stipend (i.e., participation in a class, fellowship award, and student living allowance), the stipend amount may be reported to the Internal Revenue Service (IRS) on a Form 1099 as taxable income. If the stipend amount is determined to be subject to Federal income tax, EWU will issue the recipient a Form 1099 at the end of the calendar year. PIs are advised to contact the Accounts Payable Department at the time an A-19 invoice voucher is submitted to determine if stipends on their projects are reportable to the IRS.