I. Purpose
Faculty at the University of baby直播app 鈥 Boulder may receive grants from private or federal sponsors which allow limited funds to be budgeted for childcare-related expense reimbursements.
Historically, the University of baby直播app interpreted childcare expenses to be an unallowable expense under Administrative Policy Statement (APS) 4015. APS 4015 requires that all expenses be for university business, and the university has categorized childcare expenses as a personal benefit which is not in furtherance of university business. For example, Under the Procurement Service Center Procedural Statement: Travel, the university specifically excludes 鈥渄ependent care鈥 from allowable expenses, on the basis that it is a personal benefit.
Under the CU Boulder鈥檚 Cost Principles Policy Statement, the Boulder campus holds that, when there is a conflict between external grant and university allowances, 鈥渢he most restrictive policy or guidance鈥 must be followed. Consequently, childcare expenses are not typically considered an allowable reimbursement by CU Boulder, in alignment with the university鈥檚 Procurement Service Center. However, the Boulder Campus Controller鈥檚 Office is responsible for final determinations on the allowability of certain expenditures and may issue exceptions to specific policies, procedures, or interpretations promulgated by the Procurement Service Center.
The Campus Controller鈥檚 Office has a strong interest in ensuring that any policy exception that impacts expense allowability is fair and transparent. The Childcare Reimbursement Exception Review Procedure is therefore intended to create a standardized process surrounding expense allowability determinations in the case of childcare reimbursement requests by employees who receive eligible sponsored research funding.
II. Procedure
1. Routing Exception Requests
All requests for exception involving the reimbursement of childcare expenses from research grants at the University of baby直播app Boulder should be directed to the Exception Coordinator for consideration and determination.
2.听Due Diligence
The coordinator will review the following documents before making a determination:
3.听Review Requirements
A reimbursement request must meet the following requirements:
4. Escalations
Requests presenting a novel issue will be escalated to Fiscal Compliance for review.
5. Recordkeeping
An exception determination, and any due diligence undertaken by the Campus Controller鈥檚 Office to support that determination, will be maintained for 5 years after the end of the award, or in accordance with specific award provisions, whichever may be longer.
The department is responsible for maintaining all documentation surrounding the appropriateness of the expense, including any receipts or affidavits necessary. The department must also ensure that recordkeeping complies with sponsor terms.
6. Finalizing Requests
Once a reimbursement is approved, the reimbursement will be issued as additional pay.
To process childcare expense reimbursements under an exception, the Department will need submit the request for pay via CU Time using the earnings code 鈥淎UT.鈥 This earnings code will be taxable, not incur fringe benefits, and not affect ePERs. The department will also need to ensure that the expenses are reported to the sponsor as childcare reimbursement, and not salary or benefits. For reporting purposes, childcare expense reimbursements will show on under account description of 鈥淧osition (i.e. FAC FTP) Other Ben.鈥
The baby直播app recipient is responsible for consulting with the department or the Campus Controller鈥檚 Office to ensure that costs remain appropriate in terms of service provider, cost, and payment terms. Faculty is also responsible for consulting with a personal tax advisor to determine proper reporting for these benefits. The University of baby直播app and its employees cannot provide advice on personal tax reporting obligations.
7. Exception Procedure Review & Update
This document will be reviewed, as needed, to account for periodic increases in federal childcare allowances.
III. Resources
Addendum: Novel Issues & Decisions
Issue | Request | Decision |
---|---|---|
Should a non-licensed provider be eligible for reimbursement? | Faculty member sought reimbursement from NIH of expenses associated with a climbing gym. The climbing gym was not a licensed childcare provider in the state of baby直播app. Faculty argued that baby直播app does not require licensing for providers that issue instruction in a single sport, such as climbing. The baby直播app member argued that the use of the climbing gym should therefore be permissible. |
No. A provider must have an active childcare license in the State of baby直播app. The childcare provider must have adequately satisfied any requirements deemed appropriate by the State of baby直播app in order to maintain their license active and in good standing (including background checks, site visits, etc.). Unlicensed providers are not eligible for childcare reimbursement by CU Boulder. This includes any situation where provider extends legal (but unlicensed and unregulated) childcare services. |
Does a pre-payment for services that will be rendered during a future period of grant performance satisfy the requirement that expenses be 鈥渁ctually incurred鈥 during the time of the grant? |
A daycare takes non-refundable annual/biannual payment prior to the school year. The payment is required as a lump sum prior to any service being rendered. Faculty member sought reimbursement for the non-refundable payment prior to the period of grant performance. |
Yes. A prepayment for future childcare services may be submitted for reimbursement. The department will be responsible for maintaining all documentation confirming: (1) pre-payment for services is required, (2) pre-payment is non-refundable, and (3) the anticipated or reserved service period coincides with the period of performance for the award. |