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.
