Reopening Cost Allowability FAQ

Can I charge personal protective equipment (PPE) or other items required for reopening my lab to my grants?

A. Generally, we should allocate costs consistently with how they have been historically managed. The treatment of these costs must reasonably follow our disclosed costing practices, along with the principles set forth in Subpart E of 2 CFR 200, which states that for a cost to be allowable it must be:

  • Reasonable
  • Necessary for the performance of the award
  • Consistent with policies and procedures that apply uniformly to both contract and grant funds and other university funds
  • Consistently treated, across like circumstances, as a direct cost
  • In accordance with Cornell policy, agency regulations, and the federal uniform guidance
  • In compliance with accounting principles and award period of performance
  • Allocable, as follows:
    • Specifically to the award
    • Benefits both an award and other work, and can be distributed in proportions that may be approximated using reasonable methods
      • If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit.
      • If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis.
  • Adequately documented

Items required by all individuals occupying campus, such as facemasks should not be directly charged to projects, unless that was a specific project need prior to the COVID-19 emergency. Costs that are specifically identified to a project – especially where historically borne by such projects – such as gloves, eye protection, or respirators should continue to be charged directly to the benefitting project(s). Costs that are necessary for the safe use of a laboratory, such as barriers, may be considered similarly to laboratory supplies or equipment and charged directly where allocable. Proper allocation means that where multiple activities benefit from the expense that the cost is allocated across all of them. Consistent treatment of such costs across the campus is important, meaning that if treated as direct costs in research labs, they must also be treated as direct costs in instructional labs.

Below are some examples. For further information about a specific award please contact Sponsored Financial Services. For more information about cost treatment, and the impact on our facilities and administrative (F&A) cost rates please contact Cost Analysis.

Sample Item Direct Charge, including sponsored funds (where allocable) College/
Department/ PI Funds, O&M
Contact Cost Analysis or Sponsored Financial Services
Building wide cleaning supplies, including hand sanitizer made available to all No Yes Yes  
Project specific items, such as gloves, eye protection, respirators, N95 masks, reagents Yes If not directly allocable    
Masks and items required generally for access to campus No Yes Yes  
Barriers or shields to separate laboratory personnel (non-capital, non-permanent) Yes If not directly allocable   If capital or permanent
Building opening costs (e.g. water flushing, recalibrating fume hoods) No Yes Yes  
Laboratory opening costs (e.g. instrument initialization) Yes If not directly allocable    
COVID-19 surveillance (e.g. thermometers, testing)       Yes