Jennifer,
 I am generally in agreement with your interpretation.  I might add
however, I believe that if the costs of a membership or subscription have
been included and justified in the proposal document (because such
membership or subscription is intregal to the performance of the
reseach) -and- such costs are consistently applied across the university by
policy, then they should be allowable on federally funded projects.  The
university would not have to consider them "fringe benefits" in the formal
sense.  Your institution might have a formal process to exempt charges of
this nature from the cost accounting standards.  Your grants office should
know how it is handled by your institution.

Rusty Okoniewski, Interim Director
IFAS Sponsored Programs
University of Florida
G040 McCarty Hall-D
PO Box 110110
Gainesville, FL 32611-0110
Telephone: (352) 392-2356
Fax: (352) 392-8479
E-mail: xxxxxx@gnv.ifas.ufl.edu
Visit IFAS Sponsored Programs Homepage
 http://grants.ifas.ufl.edu

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG]On Behalf
Of Morgan, Jennifer
Sent: Thursday, November 18, 1999 2:53 PM
To: xxxxxx@HRINET.ORG
Subject: Re: Personal membership costs charged to contract/grants

For those of you who are NIH-Centric, here is what the NIH Grants Policy
Statement has to say about dues and memberships:

"Dues or Membership Fees: Allowable as an F&A cost for organizational
membership in business, professional, or technical organizations or
societies.

Payment of dues or membership fees for an individual's membership in a
professional or technical organization is allowable as a fringe benefit or
an employee development cost, if paid according to an established
institutional policy consistently applied regardless of the source of
funds."

My interpretation of this policy is that if an employee's dues and
memberships are consistently paid as a fringe benefit, regardless of whether
they are paid from grant funds, then they can be included as a fringe
benefit.  This would have to be an institutional policy... and I would take
that to mean a published institutional policy.

Otherwise, they cannot be paid as a direct cost.  They can be paid as an
indirect cost and used as a part of the indirect cost calculation.

Jennifer Morgan, M.H.A.
Director, Office of Grants and Contracts
Western Psychiatric Institute and Clinic
University of Pittsburgh Medical Center Health Systems
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