Expenditure Guidance
This guidance document outlines the requirements for Project Investigators (PIs) at the New York Institute of Technology (New York Tech) managing grant expenditures. All grant expenditures must comply with federal Uniform Guidance (2 CFR 200), DOE grant regulations, current executive orders, and New York Tech’s institutional policies. The PI is responsible for ensuring all purchases are reasonable, necessary, allowable, and properly documented.
General Expenditure Requirements
- Allowability: The cost must be necessary for the performance of the federal award and be consistent with the award’s terms and conditions.
- Reasonableness: The cost must reflect what a “prudent person” would pay under similar circumstances. PIs should seek the lowest reasonable expense that meets the project’s needs.
- Allocability: The cost must be directly assignable to the grant project in proportion to the benefit received.
- Documentation: All expenditures must be adequately documented with itemized receipts, a clear statement of business purpose, and other required information.
Impact of Recent Executive Orders (EOs)
- In 2025, executive orders were issued to tighten oversight of federal grants. PIs must be aware of and follow these changes. Specifically, grants issued by some federal agencies were ordered to halt any activities related to Diversity, Equity, and Inclusion (DEI), environmental justice, and community benefit plans.
- PIs should communicate with the New York Tech Office of Sponsored Programs and Research (OSPAR) and Grants Officer to determine if a grant modification is necessary to align with these new EOs.
- Do not incur costs for any activities related to these suspended requirements.
Specific Expenditure Categories
All New York Tech employees receiving compensation through a grant will comply with the university’s Time and Effort Reporting Policy.
As a recipient of federal funding, New York Institute of Technology must comply with the Uniform Guidance (2 CFR 200) as well as other federal requirements for certifying time and effort expended on sponsored awards. All individuals at New York Tech who receive federally sponsored funding are expected to comply with both New York Tech policies and procedures and sponsoring agency regulations when proposing and making charges to grants, and when reporting time and effort on sponsored awards. Time and Effort certifications are subject to audit by New York Tech’s independent auditors in conformance with the Uniform Guidance.
All travel must be essential to the grant’s scope of work.
- Travel approval: Trips of three or more days require prior approval from the PI’s Director, Dean, or VP.
- Purpose: The business purpose must be clearly stated and documented.
- Airfare: Reimbursement is generally limited to coach-class tickets. Any exceptions for business or first-class airfare must be pre-approved.
- Lodging: For non-conference travel, lodging must be reasonably priced. Reimbursement is limited to twice the lodging rate set by the U.S. General Services Administration (GSA) unless additional justification is approved.
- Mileage: For personal vehicles, reimbursement is based on the GSA mileage rate. A drive-versus-fly cost comparison must be submitted if driving a long distance is preferred.
- Per diem policy: New York Tech follows GSA per diem rates for domestic travel and U.S. Department of State rates for international travel.
- Per diem calculation: On the first and last day of travel, employees receive 50% of the standard M&IE rate. If a meal is provided at a conference or by another party, the employee must deduct it from their per diem allowance.
- Group meals: For group meals paid for by a senior New York Tech employee, the payer must provide an itemized receipt and list all attendees. All New York Tech employees in attendance must deduct the meal from their per diem.
- Documentation: Travel expense reports and all required receipts must be submitted within 60 days of trip completion.
This category covers expenses for individuals, often students or teachers, participating in a grant-funded conference or training program.
- Prior approval: Participant support costs require prior approval from the DOE.
- Justification: A detailed justification is required, outlining the purpose of the costs and how they directly benefit the project.
- Examples: Costs may include stipends, tuition, dependent care during travel, and conference registration fees.
- Rebudgeting: These funds cannot be moved to other budget categories without prior written sponsor approval.
- Definition: Supplies are items with a unit cost below the federal equipment threshold ($5,000) and New York Tech’s capitalization policy, typically for consumable or low-cost items.
- Justification: Documentation should describe the item, its purpose, and how it is necessary and allocable to the grant.
- Purchasing: PIs must follow New York Tech’s purchasing policy, which mandates using a university purchasing card (PCard) or a purchase order for supplies, especially when buying IT equipment, office supplies, or items from vendors like Amazon or WB Mason.
- Prohibited purchases: Personal funds cannot be used to purchase IT items, furniture, equipment, or gift cards
Equipment is defined as tangible property with a per-unit acquisition cost of $5,000 or more and a useful life of more than one year.
- Prior approval: Equipment must be listed and justified in the original proposal budget.
- Justification: Provide an itemized list of all equipment, including unit cost, useful life, and justification for its necessity and allocability to the project.
- Purchasing: Equipment purchases must be made via New York Tech’s standard purchase order process and approved by ITS or facilities management. Personal purchases are strictly prohibited.
- Consultant selection: Consultants and evaluators must be chosen through a competitive procurement process, especially for costs over $10,000.
- Contracts: A contract or agreement is required for all service arrangements, regardless of dollar amount.
- General-purpose equipment: The purchase of general-purpose equipment (e.g., office furniture, IT devices) is generally unallowable unless specifically justified and approved.
- Documentation: The grant budget justification must detail the consultant’s name, services, and flat or daily rate. PIs must document that the consultant provides an independent, professional service and that the service is necessary to accomplish the grant’s goals.
- New York Tech employees: New York Tech employees cannot be paid as external consultants
New York Tech Policy References
For further details on procurement procedures and travel rules, PIs should consult the following New York Tech policies:
- Travel and Business Expense Reimbursement Policy: Covers requirements for travel approval, lodging, meals, incidentals, and documentation.
- Financial Affairs Procurement Guidelines: Outlines bidding requirements for larger purchases, vendor selection, and contract procedures.
- P-Card General Guidelines: Provides rules for using university purchasing cards, including prohibited purchases and reconciliation requirements.
Approval Process Overview
For any expenditure, the PI must provide documentation to the appropriate New York Tech financial office (e.g., OSPAR, Financial Affairs) that clearly demonstrates compliance with all applicable regulations and policies, including:
- Grant award terms: Ensure the expense aligns with the approved grant budget and scope of work.
- Uniform Guidance (2 CFR 200): Show the expense is reasonable, allowable, and allocable.
- DOE regulations: Comply with any specific requirements or restrictions imposed by the Department of Education.
- Executive Orders: Confirm the expenditure does not support any activities that have been suspended by presidential action.
- New York Tech internal policies: Adhere to all New York Tech policies.