Rusty-
At my institution (University of Pittsburgh) they are not allowed at all.
As a former institutional official, I will say that I would be very
disinclined to sign off on a budget that had them on there.  It screams COME
AUDIT ME!

I would be interested in a specific example of how a person's membership
dues would directly relate to the scope of work of a project rather than the
person's general development and academic responsibilities.  The only thing
I could come up with would be if a person wanted to present data from the
project at a scientific meeting that only allowed members to present.  Even
then, I would have trouble unless the sponsor had approved in such a way
that it doesn't look as if it just slipped through the cracks.

NIH has said that they do not consider something being on a budget as tacit
approval to bill as direct things that are normally treated as indirect.
The responsibility to monitor lies with us... as well as the liability for
violations.
-Jennifer

Can anyone else think of what might be considered an exception?

Jennifer Morgan, M.H.A.
Director, Office of Grants and Contracts
Western Psychiatric Institute and Clinic
University of Pittsburgh Medical Center Health Systems
3811 O'Hara Street, Pittsburgh PA  15213
Voice:  412-624-0743  Fax:  412-624-0714

> -----Original Message-----
> From: Rusty Okoniewski [mailto:xxxxxx@GNV.IFAS.UFL.EDU]
> Sent: Thursday, November 18, 1999 3:25 PM
> To: xxxxxx@hrinet.org
> Subject: Re: Personal membership costs charged to contract/grants
>
>
> 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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