Sales and Service Accounts

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.

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Distinguishing 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:  

Comparison

 

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

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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.