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OSP Policies & Forms

Policies & Forms

Policy Definitions


Allocable Cost (200.405): An item of cost assigned to one or more cost objectives, in reasonable proportion to the benefit provided or other equitable relationship. The cost must have a direct benefit to and be directly associated with the project(s) being performed. A cost is allocable to a particular sponsored project, if the goods or services involved are chargeable or assignable in accordance with relative benefits received or other equitable relationship. Allocability is a basic conditions that must be met in deciding whether a particular expenditure is appropriate to a particular project . 

Allowability (200.403): The determination of whether or not costs can be charged to a sponsored project as a direct or F&A cost. Costs that are directly related to a sponsored project, must benefit the sponsored project in the proportion to the amount charged, and must conform to the policies and procedures of the institution.

Authorized Official: A person to whom authority has been delegated in writing to approve expenses for meals, light refreshments, and other amenities described within the policy. The Approving Authority cannot approve transactions reimbursing themselves, expenses of a person to whom they report, or of a spouse or family member. The exception is the approval of the Executive Director’s reimbursements, which must be approved by their supervisor.

Auxiliary: An Auxiliary Organization as defined in Executive Order No. 698. By means of an Operating Agreement between California State University San Marcos and the California State University San Marcos Foundation, it is acknowledged that, with one exception, the CSUSM Foundation shall act as the administrator and financial liaison for all externally funded grants, contracts, and special projects. As an exception to this delegation, with the approval of the Chief Financial Officer, CSUSM Associated Students, Inc. (ASI) may administer externally funded grants, contracts, and special projects that were generated to benefit ASI programs. The CSUSM Foundation, and by exception, ASI Inc, will act as fiscal agent for awards and have responsibility for award compliance and financial administration, including determinations regarding overhead and administrative costs, within University policy and practice. The management of grants, contracts, and special projects will follow the procedures set by the CSUSM Foundation. All exceptions to this policy will require approval from the University's Chief Financial Officer/Vice President of Finance and Administrative Services.

Award: Umbrella term used to include sponsored grants, contracts, and cooperative agreements.  A federal award is any form of financial assistance received from a federal awarding agency directly or indirectly from a pass-through entity.

Campus: In ICSUAM Section 11000 for Sponsored Programs, campus means either the University or the Auxiliary/Foundation.

Compensated Effort: Compensation for effort consisting of campus assignment, reimbursed time, additional employment, direct pay, and cost share for faculty and staff performing services under Sponsored Projects.

Consistency: A cost is considered to be treated consistently when the expense is treated as either a direct or F&A cost under like circumstances. Consistent treatment occurs when a cost incurred for the same purpose in like circumstances is treated consistently as either a direct or an indirect cost. Consistency is a basic condition that determines whether an expense is appropriate to a particular project. 

Contract: An agreement between CSUSM or Auxiliary and a sponsor to provide an economic benefit, generally in the form of services, for compensation.  The agreement is binding and creates a quid pro quo relationship between the parties.

Contractor:  See Vendor/Contractor.

Cost Sharing: - Represents that portion of project or program costs not borne by the sponsor (generally the federal government). Cost sharing can be voluntary or mandatory (that is, required by means of a statute or law), and can take the form of either cash or in-kind contributions.

  • Cash: Represents actual verifiable expenditures from the recipient or from non-Federal third parties – and includes costs incurred by the University or Auxiliary, including indirect costs.
  • In-kind: Represents the value of all noncash contributions, including services and property provided by non-Federal third parties.
  • Mandatory: Required by the sponsor or funding agency supporting the sponsored project. Some sponsors require that the recipient of an award provide some level of cost sharing or matching costs as a condition of receiving the award.
  • Voluntary: That portion of the project costs that the campus provides on its own initiative when the sponsor does not require cost share or the amount of cost share provided is more than the sponsor’s mandatory requirement.
    • Voluntary Committed: Quantified and included in the proposal budget and award and becomes a binding requirement of the award.
    • Voluntary Uncommitted: Effort that is over and above that which is committed and budgeted for in a sponsored agreement. Voluntary uncommitted effort is not required to be documented or tracked.

Direct Costs: Direct costs are those costs that can be identified specifically with a particular final cost objective, such as an award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect (F&A) costs.

Facilities and Administrative (F&A): See Indirect (F&A) Costs

Gift: Any item of value given to CSUSM Corporation by a donor who expects nothing of value in return, other than recognition and disposition of the gift in accordance with that donor's wishes. There is no formal fiscal accountability to the donor beyond periodic progress reports and summary reports of expenditures. These reports may be thought of as requirements of good stewardship, and, as such, may be required by the terms of a gift. They are not characterized as contractual obligations or "deliverables."

Grant: A financial contribution to a recipient to carry out an approved project or activity. A grant generally anticipates no substantial programmatic involvement of the sponsor with the recipient during performance of the project or activity, but sponsors usually require deliverables/progress reports and/or final report – and an accounting of the use of funds or return of unused funds.

Grant Agreement: Grant agreement means a legal instrument of financial assistance between an awarding sponsor or pass-through entity and another entity.

Grant Capacity: An institutionʹs potential volume of grant activity while considering  qualification, complexity, and suitability.

Grant Readiness: A relative level of preparation to pursue grant activity, both in general and in respect to specific projects and opportunities.

Indirect (F&A) Costs: Those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived. (From UG §200.56)

Principal Investigator: The individual (whether referred to in the contract or grant as a Principal Investigator, Project Director or other similar term) designated by the Sponsored Program Administrator to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the Sponsored Program. 

Investigators:  (Financial Conflict of Interest #11010.02)

Nongovernmental Investigator: For non-governmentally funded projects, a Principal Investigator (“Investigator”) who has primary responsibility for the scientific and technical conduct and reporting of a research project funded by a nongovernmental entity.

PHS Investigator: Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.

NSF Investigator: The term "Investigator" means the principal investigator, co-principal investigators/co-project directors, and any other person at the organization who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF.
Note: For purposes of policy #11010.02, regardless of funding source, "Investigator" also includes the investigator's spouse/domestic partner and dependent children. 

Reasonableness (200.404): A cost is reasonable if the nature of the goods or services acquired or applied, and the amount involved therefore, reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. Reasonable costs that are generally recognized as necessary for the operation of a sponsored project, have an arm’s length relationship between the vendor and the principal investigator and/or institution, and are consistent with sponsor and institutional policy. Reasonableness is a  basic condition that must be met in deciding whether a particular expenditure is appropriate to a particular project.

Recipient: CSUSM or Auxiliary designated as the ponsored Program Administrator and awarded a contract or grant. The recipient is either the University or Auxiliary, as the case may be, even if a particular component is designated in the award document, and shall not be an individual, department or other constituent unit. 

Research: From 45 CFR 46.102, “Research means a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge.” The term encompasses basic and applied research. Basic research is defined as systematic study directed toward fuller knowledge or understanding of the fundamental aspects of phenomena and of observable facts without specific applications towards processes or products in mind. Applied research is defined as systematic study to gain knowledge or understanding necessary to determine the means by which a recognized and specific need may be met.

Salary Cap: A limitation imposed by the sponsor on the amount of salary that can be directly charged to projects.

Significant Financial Interest: Anything of monetary value, including but not limited to salary or other payments for service (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options); being an owner, partner, director or officer in a non-publicly held company or entity; and, intellectual property rights (e.g., patents, copyrights) and royalties from such rights. Refer to the CSU FCOI Disclosure Requirements by Funding Source Chart for specific definitions for each funding source.

Sponsor: The party/entity paying for services or other economic benefit under a contract or providing financial assistance/contribution for a project or activity under a grant.

Sponsored Agreement: A contract, grant, or other agreement from a sponsor to the campus.

Sponsored Projects:  A project resulting from a grant, contract, or other agreement between the campus and a sponsor.

Sponsored Program: All work performed under grants or contracts funded by non-CSU funding sources (including non-CSU-funded contracts and grants that are subsequently subcontracted to another campus).

Sponsored Program(s) Administrator: The entity (Foundation, University or Auxiliary) designated by the University to administer the Sponsored Program.

Sponsored Program Records: Include, but are not limited to, accepted proposals and applications; contracts or grant agreements; program reports and data; correspondence; budgets and supporting financial documentation; supporting human resources documentation; and other records relating to receipt, review, award, evaluation, status and monitoring of the sponsored program.

Sponsored Program Work Product: Any work created in the performance of a sponsored program. Unless the contract or grant states otherwise, sponsored program work product does not include journal articles, lectures, images, books or other works that are subject to copyright protection and have been created through independent academic effort and based on the findings of the sponsored program.

Sponsored Project:  A project resulting from a grant, contract, or other agreement between the campus and a sponsor.

Subaward: An award (subgrant or subcontract) of financial support from a prime awardee/pass-through entity to a qualified organization for the performance of a substantive portion of the programmatic effort funded under the prime award. This term also includes awards made by a sub-recipient to a lower tier subrecipient. It does not include payments to a contractor or payments to an individual that is a beneficiary of the program.

Subrecipient: The legal entity to which a subaward is made and which is accountable for the use of the funds provided in carrying out a portion of the prime awardee’s/pass-through entity’s programmatic effort under a sponsored project. A subrecipient has responsibility for programmatic and/or administrative decision making and adherence to the applicable sponsor program compliance requirements. The term may include institutions of higher education, non-profit organizations, for-profit corporations, and foreign or international organizations at the discretion of the federal awarding agency.

Unallowable Costs: Costs that are explicitly identified as unallowable or those that do not meet the conditions for allowability.

University: One of the campuses of the California State University or the Office of the Chancellor.

Unlike Circumstances: An activity or cost, which is substantially greater in amount or different in purpose than the normal use.  The term "unlike circumstance" comes from several citations in federal cost principles.  The government requires that costs incurred for the same purposes be consistently charged either as direct costs or as indirect costs.  To allow a charge normally included as indirect as a direct charge, there must be unlike circumstances.

Uniform Guidance (2 CFR 200): The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) are the federal regulations for the management of federal awards.  The Uniform Guidance streamlines and supersedes guidance that was previously contained in eight different OMB Circulars (including A-21, A-110 and A-133). 

Vendor/Contractor: A vendor/contractor is responsible for providing goods or services necessary to conduct the research or other programmatic effort, but is not responsible for the results of the research or effort. vendors/contractors provide similar goods or services to many different purchasers. A vendor/contractor is only required to meet the terms of the procurement agreement and is not subject to compliance requirements of a federal (or other) sponsor.​