Sales and Service Accounts
- Distinguishing between Sales & Service and Sponsored Activities
- Use of equipment originally purchased with federal funds involved in generating Sales & Service revenue
In some cases, a department/center/institute may receive funding for providing goods/services or services for a fee to the external community. Always route agreements to ORSP for review prior to running an activity through a sales & service account to ensure compliance with UM guidance and Montana Board of Regents Policy 1909.
⇑ Back to topDistinguishing Sales & Service from Sponsored Activity
The following distinctions are illustrative only. but may be helpful in providing general guidance when an activity is a sponsored program:
|
|
Sales and Service |
Sponsored Program |
| Note: If federal funds or federal pass through funds are involved, always route to ORSP for review. | ||
| AOR Signature | Never requires institutional signature; if required, route to ORSP to review | Usually requires Authorized Organizational Representative (AOR) signature on behalf of institution. |
| Award Mechanism | Never accomplished via cost-reimbursable award mechanism | Accomplished via specified award mechanism (e.g., fixed price or cost-reimbursable agreements) |
| CFDA, Cost Match, F&A, or FAR Clauses | Never cites a CFDA number, cost match, an MOU/MOA, F&A, or FAR clauses | May involve cost match, F&A recovery, cite FAR clauses, or an MOU/MOA |
| Commercially Available | Sale of products or services (e.g., printing/photocopy, laboratory analysis) that could be commercially purchased; price determined by established fixed-fee schedules; data belongs to purchaser | Specific deliverables are expected per sponsor terms and conditions; collaborator relationship exists (e.g., joint publication expectations) |
| Income | Activities generate net income, usually from an aggregate per service/unit sale | Activities typically do not generate net income |
| Indemnification / Hold Harmless | Indemnification/hold harmless language is never included; if included, route to ORSP to review | Indemnification/hold harmless language may be included in terms |
| Intellectual Property (IP) | Activity never includes intellectual property (IP) concerns | Activity may include IP concerns |
| Purchaser Provides Samples | Samples (or content/material) generally provided by Purchaser | Researcher may collect samples (or provide content/material) |
| Purchaser Requests Services | Activity typically originates when Purchaser requests services | Activity usually originates when a proposal is submitted to sponsor |
| Reporting Requirements | Reporting requirements (e.g., financial, time & effort, etc.) or federal assurances never required | Reporting required (e.g., financial, time & effort, etc.) |
| Research Compliance | Never involves UM employee securing regulatory research compliance approvals (IRB, IACUC, IBC, etc.) | Regulatory research compliance approvals may be required |
| Scholarly expertise / Oversight | Activities generally do not require any intellectual interpretation or scholarly expertise, nor principal investigator oversight and involvement; if included, route to ORSP to review | Activities require specific intellectual interpretation or scholarly expertise, and principal investigator oversight and involvement |
| Venue / Law / Insurance | Choice of venue/choice of law or insurance requirements are never included; if included, route to ORSP to review | Choice of venue/choice of law or insurance requirements may be included in terms and conditions |
This determination checklist is a helpful tool to help identify whether an activity is more appropriate to be administered via a Sponsored Program. It is not conclusive. Contact ORSP for input and review.
If equipment originally purchased with federal grant funds are involved in generating any Sales & Service revenue, the Department (Center, Institute, etc.) is responsible to ensure that use of equipment is compliant with Uniform Guidance 2 CFR 200.313.
For further information, contact your accounting liaison in Business Services or ORSP.