Buying Computers on Grants under the New Federal Uniform Guidance
Purchasing Computing Devices with Federal Funds (applicable Uniform Guidance Sections 2 CFR Part 200.20 and 200.453)
Computing devices are machines used to acquire store, analyze, process, and publish data and other information electronically and include accessories for printing, transmitting and receiving, or storing electronic information. If a computing device is to be acquired for the use in the performance of a federal award, the computing device may be charged to the award provided that:
- It is essential (i.e. necessary) to perform the work under the award, and
- The cost is allocable and reasonable.
How do you determine if a device is essential (i.e. necessary)? Consider, and be sure to document, whether performing the work under the award without the computing device would be difficult and inefficient.
How do you determine if a device is allocable to an award? If a computing device is essential to a federal award, then it is allocable to that award. The total cost may be allocated to the benefiting award, even when its usage is not solely dedicated to the award. If the device is not essential, none of the cost may be charged to the award.
How do you determine if the cost of a computing device is reasonable? The Principal Investigator must make an informed, prudent decision taking into consideration not only the cost, but the utility, quality and value of the device to the project.
The MOST important thing to remember when charging computing devices to a federal award is to document the criteria outlined in this segment. Written documentation is required. Without written documentation, proof that the charge is essential, allocable, and reasonable never happened (conversations, research on cost, etc.).