Inclusion of Memberships, Subscriptions and Professional Activity Costs on Sponsored Projects
I. Procedural Statement
This document is intended to serve as formal guidance for Boise State University regarding the use of funds from sponsored projects for memberships, subscriptions, and professional activities in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored research. Procedural statements support the University’s Basics of Charging Costs to a Sponsored Project by providing definitions and processes for meeting those standards in like circumstances.
Boise State University defines memberships, subscriptions, and professional activities as:
Memberships are fees or dues paid for an individual or an institution to join a technical, business, or professional organization for a specific length of time. Individual memberships are associated with, and provide benefits to, a single person only. Institutional memberships are associated with, and provide benefits to, an entire non-federal entity (Boise State University).
Subscriptions are payments in exchange for receiving technical, business, or professional periodicals or access to information (ex. inter-library searches or national DNA database).
Professional activities are intended to enhance an individual’s professional development, including obtaining skills and qualifications in order to progress in his/her career.
A. Federal Awards
Under the guidelines imposed by the U.S. Office of Management and Budget’s Uniform Guidance (2 CFR 200.454), costs for institutional memberships in business, technical, and professional organizations and institutional subscriptions to business, technical, and professional periodicals are allowable. The costs of the University’s membership in business, technical, and professional organizations, and subscriptions to business, technical, and professional periodicals are allowable when they provide a direct benefit to the project. The cost of memberships in any civic or community organization is allowable with the prior approval of the federal awarding agency or pass-through entity. These costs must be itemized in the budget and described in the budget justification, or receive prior written approval from the sponsor before the incurrence of such costs.
Membership fees or dues, such as airline, social, dining and country club dues, cannot be charged directly to federal or non-federal sponsored projects.
Individual memberships are typically treated as indirect costs per 2 CFR 200 Appendix III.B.6.b.(2).
1. Boise State University receives an award with an institutional allowance, and the Federal agency specifically allows direct charging of individual dues, or memberships, or subscriptions. Examples of these types of awards include NIH or NASA fellowships, training projects, or any other type of award with an institutional allowance. The membership, subscription, or professional activity cost should directly benefit the fellow or participant.
2. In specific situations where the government would ultimately save money by paying for an individual membership, because it would benefit the University and the Federal government and not just the individual.
a. If a faculty member, senior person, or student needs to attend a conference as part of the award’s approved Scope of Work (and the costs are otherwise “necessary” and allowable under 2 CFR 200.403(a)). The individual membership cost is incurred specifically for the Federal award (2 CFR 200.405(a)(1)) or specifically for the Federal award and other work of our University with costs allocated to the Federal award only in proportion to the direct benefit to the Federal award (2 CFR 200.405(a)(2)). The cost of the conference before the individual membership is, let’s say $800, but only $300 after paying a $50 individual membership (so the cost to the Federal government is reduced from $800 to $350) (and the costs otherwise meet the reasonableness standard (2 CFR 200.404).
B. Non-Federal Awards
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, the procedural statements are also applicable to non-Federal awards. The basic criteria for membership, subscription, and professional activity costs are similar for non-Federal sponsored projects, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of membership, subscription, and professional activity costs should be provided in order to explain why these are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.
The only time that costs for dues, memberships, subscriptions, or professional activities will be included on a Federal proposal is when the sponsor specifically allows these types of costs through an institutional allowance, or other identified support for career development.
Some non-Federal sponsors may allow dues, membership, subscriptions, and professional activity costs to be direct charged. Review of the requirements and restrictions of the non-Federal sponsor is required to ensure allowability. If allowable, these costs should be identified in the proposal budget justification as to why they are necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the costs. Written justification and approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
After an Award is Funded
Some federally sponsored programs (typically NSF, NIH, and USDA) which award fellowships to graduate students and postdoctoral scholars also provide the University with an Institutional Allowance instead of indirect costs to defray the individual and/or institutional costs of education or training. The Institutional (or Cost of Education) Allowance is included in the overall award budget. The allowance is expected to be spent timely and within each budget year. It should be rare to have unused funds.
Typically, when Boise State University receives an institutional allowance, it is coded to Other Expenses Budget in PPM. Review of the award document may be necessary to confirm that an institutional allowance was received. In addition, sponsor requirements and restrictions related to institutional allowances should be reviewed to ensure the institutional allowance may be used for these types of costs. Education or training-related expenditures often include travel to research-related conferences or symposia, conference fees, books, fees, health insurance, research supplies, etc. The fellow’s stipend and tuition are usually separate line items from the institutional allowance within the overall award budget.
Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted (not specifically identified in the budget justification submitted with the proposal) membership, subscription, or professional activity cost is required after a non-Federal award is funded, the PI or department administrator should work directly with their SPA to document the necessity and benefit of the cost. If sponsor approval is required, the SPA will contact the sponsor for approval. The sponsor approval (if required), as well as the written justification explaining the need and benefit of the cost to the specific project, will be retained by the Office of Sponsored Programs for future reference should the expenditure be questioned at a later date.
I received an NSF award including participant support costs. The budget for participant support includes stipends and an institutional allowance. May I charge membership fees for the participants to the participant support project?
Yes, you may charge membership fees to the participant support project if there is budget available from the institutional allowance, and if the membership fees are in support of the participants. The institutional allowance may not be used to pay membership fees for the PI or other Boise State University faculty or staff. It is not allowable to charge membership fees to NSF participant support awards that do not have an institutional allowance.
I have an appointment on an NIH training grant at Boise State University. I would like to travel to Georgia Tech for specialized training related to my research and charge the cost of the travel to the training grant. Is this an allowable professional activity cost?
Yes, with prior written approval from NIH, costs for travel and registration fees for the specialized training are allowable professional activity costs on the training grant.