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 ~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~= 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/ ~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~= 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> > > > > > > ====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available via > our web site at http://www.hrinet.org (click on "Listserv Lists") > ====================================================================== > ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
