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Plain-English guide · for nonprofits

2 CFR 200.403, explained in plain English

Updated October 2026

§200.403 sets eight tests for charging a cost to a federal award. The cost must be needed, reasonable and belong to the award. It must stay within limits and follow your own policies. It must be treated the same way each time and follow standard accounting rules (GAAP). It cannot count as match on another award. And it must be documented and spent in the budget period.

The short version

Adequately documented, (g): you can prove the cost with a record, like an invoice, receipt, approval or time record. The period rule, (h): the cost has to fall inside the approved budget period. Administrative closeout costs are the one exception. Charging salaries? The free time and effort certification template gives you that record for staff time.

The tests

§200.403 is the gate in the Uniform Guidance that every cost passes through. Fail any one test and the cost is unallowable, however sensible it seemed.

  1. (a) Necessary and reasonable, and allocable to the award

    Would a prudent person in your position have incurred it, at that price, for this award? Allocable is a separate idea and gets its own section at §200.405.

  2. (b) Within any limits the rules or the award set

    Cost principles exclude some cost types outright. Your award's terms can exclude more, or cap them.

  3. (c) Consistent with policies that apply to all your work

    The same rule for federally funded and non-federally funded activity. A mileage rate that is generous only on the grant fails here.

  4. (d) Treated consistently as direct or indirect

    A cost incurred for the same purpose in like circumstances cannot be a direct cost on one award and sit in your indirect pool on another.

  5. (e) In line with GAAP

    With carve-outs for state and local governments and Indian Tribes.

  6. (f) Not used as cost sharing on another federal award

    In this period or a prior one. That is the cost-sharing rule at §200.306.

  7. (g) Adequately documented

    Plain answer: you can prove the cost with records, such as an invoice, a receipt, an approval or a time record. Paragraph (g) points you to §§200.300 through 200.309, the financial management standards, for what counts as a record. A real cost with no record behind it is an unallowable cost.

  8. (h) Incurred in the budget period

    Plain answer: every cost must be incurred during the approved budget period. A budget period is one funded part of the period of performance, so a cost outside the period of performance generally fails this test too. Paragraph (h) makes one exception: administrative closeout costs may be incurred through the final report due date and must be liquidated by then, charged to the final budget period unless the agency says otherwise. Pre-award costs are a separate case: with the agency's written approval under §200.458, costs incurred before the start date may be charged to the initial budget period. Closeout itself is §200.344.

Two to get right first

Consistent treatment. If your executive director's time is a direct charge on the federal award but sits in overhead everywhere else, you are charging twice for the same kind of cost. The fix is a written cost allocation policy that says which costs are direct and which are indirect, applied to everything.

Documentation. Auditors do not disallow costs because they think you did not incur them. They disallow them because you cannot show it. Payroll charged by memory rather than by a certified time record is one version, and it lives at §200.430.

What to actually do

  1. Write the cost allocation policy once

    One page naming which cost types are direct and which are indirect, applied to every funding source. It answers test four permanently, and it is the kind of written control §200.303 on internal controls asks for.

  2. Attach the evidence at the moment of the cost

    Receipt, invoice, approval, and which award it hits. Reconstructing a year later is where costs get disallowed. §200.302 on financial management already requires source documentation behind every record.

  3. Check the award terms, not just the regulation

    Awards can restrict costs the Uniform Guidance would allow.

This is general information, not legal or accounting advice. Federal grant rules change and are applied differently by different agencies and auditors. Check with your auditor, your grant officer, or an attorney before relying on any of it.

The Ember tool for this

Ember Budget

Ember Budget tracks money in and out by program and keeps restricted funds apart from flexible funds. Unlimited users on every tier.

Sources: 2 CFR Part 200 (eCFR), read 29 August 2026, re-checked 1 September 2026 and again 3 October 2026. Federal grant rules change; check the current text before relying on this.

Common questions

What makes a cost allowable under a federal grant?

Under 2 CFR 200.403 a cost must be necessary and reasonable for the award and allocable to it, conform to any limits in the cost principles or the award, follow policies applied uniformly to federal and non-federal work, be treated consistently as direct or indirect, accord with GAAP, not be used as cost sharing on another federal award, be adequately documented, and be incurred during the approved budget period.

What does 'reasonable' mean for a grant cost?

A cost is reasonable if a prudent person would have incurred it under the circumstances prevailing when the decision was made. It is a judgment about both the decision to spend and the amount spent, not a fixed dollar test.

Can the same type of cost be direct on one grant and indirect on another?

No. 2 CFR 200.403 requires consistent treatment: a cost incurred for the same purpose in like circumstances must be treated either as a direct cost or as an indirect cost, not both. A written cost allocation policy applied to all funding sources is how organizations satisfy this.

What happens if a cost is not documented?

It is treated as unallowable. 2 CFR 200.403 lists adequate documentation as a condition of allowability, so a cost that was genuinely incurred but cannot be evidenced can still be questioned and disallowed at audit.

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