Grant-funded peptide purchases: documentation for allowable cost and audits

The tests every supply cost has to pass

The Uniform Guidance at 2 CFR 200.403 lists the factors that make a cost allowable. The cost must be necessary and reasonable for the award and allocable to it; conform to limits in the principles or the award; follow policies applied uniformly to federal and other work; be treated consistently; follow generally accepted accounting principles; not be counted toward another federal program; and be adequately documented. [2]

Allocable has a specific meaning in 200.405: the cost is incurred specifically for the award, or benefits the award and other work in proportions that can be reasonably estimated, or is necessary to overall operations and can be partly assigned. When a cost benefits several projects and the shares can be worked out without undue effort, it is allocated in proportion to benefit; where the work is too interrelated, any reasonable documented basis may be used. [3]

We read these sections on Cornell Law School's Legal Information Institute because the official eCFR site would not load for us on 30 October 2026. Check the current text on eCFR or with your sponsored-programs office before relying on a quotation.

What the rules say about supplies specifically

Section 200.453 makes materials and supplies necessary for an award allowable, charged at their actual prices net of applicable credits, and says incoming transportation charges are an allowable part of the cost. [4] A refund, discount credit or replacement-without-charge therefore has to be reflected in what the award pays.

The NIH Grants Policy Statement repeats these points and says materials and supplies used for an award may be charged as direct costs. [1] The supply and equipment line is drawn in 200.1: equipment has a useful life of more than one year and a per-unit cost at or above the lesser of USD 10,000 or the institution's capitalisation level; everything else tangible is a supply. [5] A peptide order is a supply at any realistic research price.

How long to keep the records

Section 200.334 sets three years from the date the final financial report is submitted. The period extends if litigation, a claim or an audit starts within the three years, until it is resolved; an agency or pass-through entity can also extend it in writing. [8] Your institution may set a longer period. The clock starts when the final financial report is submitted, not on the date of purchase (for awards renewed quarterly or annually, it runs from each quarterly or annual report), so a supply bought early in a multi-year award can need to be retrievable years after the order. [8]

Per-order evidence checklist

Each item below answers one of the questions an auditor asks: was it needed, was the price reasonable, was it bought properly, did it arrive, and was it used on this award? File them together under the order number.

Worked example: one lot, two projects

A lab buys one 50 mg lot of a peptide for USD 600 plus USD 40 inbound shipping. Two NIH awards will use it: award A plans 30 mg and award B 20 mg, based on the experiment plans. The shares can be worked out, so 200.405(d) calls for proportional allocation: USD 384 (60 percent of USD 640) to A and USD 256 to B, with the shipping included because inbound freight is part of the supply cost. [3] [4] The allocation note, the two experiment plans and the inventory log showing actual withdrawals are the documentation. If actual use departs materially from the plan, follow your institution's policy on adjusting the charge.

Figures in this example are invented for illustration; the rules are from the sources.

Common gaps

Card statements without itemised receipts. Orders that list a product but no lot, so the certificate cannot be tied to the purchase. Usage that lives only in someone's memory. Quotes that were never saved because the price was on a web page that has since changed. Each gap is cheap to close at the time of purchase and expensive to reconstruct years later.