Unrestricted Fund Expense Policy

Effective Date:

December 26, 2014



Policy Review Date:

July 1, 2015

Issuing Authority:

Research Foundation President

Responsible Party:

Chief Financial Officer

Contact Information:



Reason for Policy

Under the 1977 Agreement between the Research Foundation for The State University of New York ("Research Foundation" or "RF") and the State University of New York (SUNY), the RF administers funds that are received from the federal government and other authorized sources to support research, education, and other institutional activities of SUNY. This policy ensures proper stewardship and appropriate use of funds received through:

Statement of Policy

Expenditures of Unrestricted Funds must be used to fund expenses of the RF central office, RF operating locations, or SUNY that support:


Exceptions to specific aspects of this policy may be made as set out within this policy, or by written waiver by the operations manager or an officer of the RF with detailed substantiation justifying the exception or waiver, and subject to the general policy requiring any expenditure to be reasonable, necessary, and appropriate.

Examples of Permissible Expenses

Expenditures that are permissible may be paid directly or reimbursed from Unrestricted Funds. The following list highlights examples of expenditures that generally are permissible and does not identify every expenditure that is permissible.

Examples of Non-Permissible Expenses

Non-permissible expenses must not be paid or reimbursed from Unrestricted Funds and must be paid out-of-pocket by the employee. The list below highlights expenditures that are generally not permissible, but is not intended to identify every non-permissible expenditure.

Unrestricted Fund Expenses and the Facilities and Administrative (F&A) Cost Rates

Expenses from unrestricted funds are included in the periodic calculation of Facilities and Administration (F&A) rates, and for the purpose of completing the F&A cost proposal the F&A rates must include only federal allowable costs as defined by OMB 2 CFR Part 200. As such any federal unallowable expenditures of Unrestricted Funds from indirect cost recovery must be charged to one of the expenditure types identified as unallowable. (This process is often referred to as a "scrub" of unallowable costs from the F&A rate.) Federal Unallowable Expenses must not be charged to federally funded (direct or flow-through) awards or projects or to cost sharing on a federally funded award.


The following table outlines the responsibilities for compliance with this policy:

Responsible Party


Every individual who initiates, processes, reviews, approves, or records financial transactions on behalf of the RF.

Responsible for complying with and administering this policy.

Outside parties

Outside parties who incur business expenses for or on behalf of the RF are responsible for compliance with this policy.

Operations Managers or designee

Responsible for oversight and management of implementation of this policy at operating locations.


Discretionary Spending Accounts- Refers to an account or sum of money under the control of a listed person with respect to which he or she is not accountable to the organization, whether or not actually used for any personal expenses as defined on Schedule J of the Form 990.

Federal Unallowable Costs- Expenses that are not reimbursable by the federal government, under regulations identified in OMB Circular A-21.

OMB 2CFR Part 200- The federal regulations for administrative requirements, cost principles and audit requirements for federal awards.

Permissible Expense- A necessary, reasonable, and appropriate expense incurred for the benefit of the RF or SUNY and therefore permitted to be reimbursed or paid directly from Unrestricted Funds.

Shared Services- Campus related organizations that use RF human resources, payroll or purchasing/payables administration services and pay fees that are included in Unrestricted Funds.

Tax indemnification and Gross-up Payments- Organizations payment or reimbursement of any tax obligations of a listed person on Schedule J of the Form 990.

Related Information

Travel Site

Credit Card Programs Policy

Documentation Guidelines for Purchasing and Payment Activities

Fixed Price Balance Awards

Procurement Site

Excerpts of Unallowable Costs



On or after December 26, 2014, 2 CFR Part 200 is effective and applies to all new awards issued. Funding awarded prior to this date and/or incremental funding may still be governed by OMB Circular A-110, A-21 or A-133, depending on the awarding agency’s specific terms and conditions.

Change History


Summary of Change

December 26, 2014

Updated for change to 2 CFR Part 200.

December 7, 2012

New policy. Effective 3/15/2013



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