Re: Memberships Costs on Federal Grants Michael DeShazo 24 Jan 2006 16:19 EST

Dear Sue,
Good question!  Just recently the same question was posed by one of our
research administrators and her PI.  After some research and discussion,
below is basically (edited to protect the innocent) the response we sent.

Before that, I'll state that several institutions to whom I conferred
had written policies (including ours) that had to be considered in
conjunction with A-21.  Also, for NIH funding the GPS must be reviewed
as it has more explicit terminology relating to the allowability of
memberships.

Lastly, consider also that cost savings is typically not a justification
for arranging travel, purchasing types of supplies, subcontracting, etc.
 By extension of this concept I would say that the same holds true for
this type of cost.  Just because one can save money on a conference cost
by belonging to the society, is not in itself a reason to allow the cost.

-------------response-------------
1) Does the project have a special need for the item or service that is
not available without the membership?

 While there are certain benefits gained from membership in a
specific professional/technical organization, they are typically no
greater than the benefits that arise from belonging to most professional
organizations or associations.

2) Can the costs be specifically identified to the work conducted under
the project?

 The work from nearly every grant produces results that are
publishable and presentable, but belonging to a specific
professional/technical organization does not specifically produce
results for the grant.  In other words, while formal and informal
consultation with knowledgeable colleagues is a necessary part of
scientific work it can be done either as a part of any professional
association or from other contacts.  Thusly, it does not appear as
though this cost specifically benefits *only* this project.

3) Was the cost specified in the proposed budget of the sponsored
agreement, and the special circumstances requiring direct charging
justified in the proposal?

 It is unusual for PIs to specifically include this type cost in
the budget proposal.

4) Did the sponsoring agency accept the cost as part of the project's
direct cost budget?  That is, if it was specifically included in the
proposed budget to the sponsor, the sponsor did not specifically
disapprove the cost in the award or in other notice it has given to the
University?

 Based on the answer to #3, if the cost was not specifically
included in the proposed budget to the sponsor, then there would be no
way for the sponsor to appropriately disapprove the cost; as such we can
not use question #4 in determining allowability unless the budget
justification which specifically addresses this cost can be provided.

5) Is membership in the professional or scientific organization the only
means of obtaining a specific journal or periodical directly related to
the grant or contract?

 While most professional/scientific organizations may have a
journal that it publishes, it is highly unlikely that it is directly
related to a specific project and more likely that it is related to
various areas of scientific endeavor within a field of science.

6) Lastly, would directly placing this cost on a federally sponsored
project be consistent (as defined by Cost Accounting Standards (CAS))
with the the way the University as a whole treats this type of cost?

 The vast majority of departments and colleges within the
University pay for memberships and subscriptions from discretionary
funds or other departmental funds.

The above review hopefully illustrates why we noted that this cost
TYPICALLY is not included as a direct cost to the grant.  If unique and
unlike circumstances can be (or have been) presented, then allocability
and allowability can be appropriately discussed and determined.

Regards,
Michael DeShazo
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Budget/Fiscal Analyst Lead (CRA in-training)
Financial Compliance and Outreach, Grant and Contract Accounting
University of Washington, Box 351122

Team Email: xxxxxx@u.washington.edu

PH: (206) 616-6718
FX: (206) 543-0764
EM: xxxxxx@u.washington.edu

WEB: http://www.washington.edu/research/gca/office/
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Sue Logan wrote:
> Dear Research Administrators:
>
>
>
> I have a question for you …
>
>
>
> Per OMB Circular A-21, F.6.b.,
>
>
>
> (3) Items such as office supplies, postage, local telephone costs, and
> _memberships shall normally be treated as F&A costs_.
>
>
>
> We have a researcher that must attend an annual professional meeting as
> part of the scope of work of the project.  He is currently not a member
> of the society, but if he becomes a member, the registration costs are
> much less.  How does your university handle such a situation ?  Do you
> allow the membership cost to the professional organization for the PI to
> be charged to the Federal grant in this case ?
>
>
>
> Thank you
>
> Sue
>
>
>
> Sue Logan, CPA, CRA
>
> Director, Contracts and Grants
>
> Division of Research and Graduate Studies
>
> Florida Atlantic University
>
> 777 Glades Road
>
> ADM 210A
>
> Boca Raton, FL  33431
>
> (561) 297-2606  phone
>
> (561) 297-2319  fax
>
> xxxxxx@fau.edu <mailto:xxxxxx@fau.edu>
>
> www.fau.edu/research/ocg/index.html
> <http://www.fau.edu/research/ocg/index.html>
>
>
>
>
>
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