PHIG Policy Framework v1.2 · Policy 29 · Adopted 1 September 2026 · References: ASF Policy 24; 2 CFR 200 Subpart E (cost principles) and 200.430 (compensation, time records); EU MGA Art. 6 (eligible costs) and personnel-cost rules; Horizon Europe daily-rate method
1. Purpose and scope
To ensure that every cost charged to a donor is allowable, allocable, reasonable, consistently treated and documented, under both EU and US rules. Applies to the Board, the Director, staff, consultants, volunteers, experts, partners and suppliers of PHIG and all platforms of its network.
2. Policy
- A cost is charged to a grant only if it is allowable under that grant, allocable to it (incurred specifically for it or benefiting it in a measurable proportion), reasonable (what a prudent person would pay), consistently treated, adequately documented and not charged elsewhere.
- Shared costs are allocated by a documented, consistent method (e.g., by headcount, time, floor area) approved by the Director; the method is applied uniformly across donors.
- Indirect costs are charged at the rate the grant allows: the EU flat rate, a US negotiated indirect cost rate agreement (NICRA) if obtained, or the US de minimis rate; the same cost is never both direct and indirect.
- Time is recorded for every person charged to any grant: monthly time sheets showing hours or days per project and non-project time, signed by the person and approved by the supervisor, reflecting actual work, prepared contemporaneously; or the exclusive-assignment declaration where a grant allows it.
- Unallowable costs (fines, entertainment, alcohol, lobbying, fundraising, bad debts, contingencies, excessive travel) are never charged to grants and are coded separately in the accounts.
- Costs in foreign currency are converted at the rate the grant specifies.
3. Procedures
- Allocation method memo; time-sheet template; monthly review by the accountant.
Responsibilities
Accountant; Director; project leads.
Review
Every two years and when donor rules change.
Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).