UG-Computing Devices, Membership Fees and Publication Costs

COMPUTING DEVICES
Defines computing devices as supplies and allowable as a direct cost if essential and allocable, but not solely dedicated to the project.

Updated: 09/01/2015

Computing Devices are machines that cost less than $5,000* and are used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting and receiving, or storing electronic information.

  • Charging computing devices as direct costs is allowable for devices that are essential and allocable (provide benefit), but are not solely dedicated, to the performance of a federal award.  Such devices are also allowable if solely dedicated to the performance of a federal award.
  • Federal sponsors may impose requirements for these costs to be included in the proposal budget and may require a budget justification. Until the federal agencies release specific information, budget justifications may be used at the discretion of the principal investigator.
  • Inventory tags may be affixed to computing devices at the discretion of the department; inventory tagging facilitates accountability, availability for reuse, and appropriate disposal.

Non-federally Sponsored Projects: Direct charging of computing devices to a non-federally sponsored project is appropriate if the computing device benefits the sponsored project.  Some non-federal sponsors may have specific requirements for direct charging of computing devices and should be addressed at proposal time.

*There is no change in policy regarding treatment of items over $5,000.   If the acquisition cost of a computer is greater than $5,000 (and has useful life of more than 1 year), it should be categorized as computing equipment.

The Uniform Guidance is effective for federally sponsored agreements and new funding increments awarded on or after December 26, 2014.

Uniform Guidance Section: 200.20 and  200.453

Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-122.

 

 

MEMBERSHIP FEES
Individual memberships are not an allowable direct charge on a federally sponsored project.

Updated 09/01/2015

Do not propose or charge individual memberships (business, technical or professional) to a federally sponsored project.  An individual’s membership in business, technical, and professional organizations is generally not an allowable expense as a direct charge on a federally sponsored project.  If there are exceptional circumstances that make a membership expense an allowable, allocable, and reasonable charge to a federally sponsored project, please work with the Office of Sponsored Programs to review the circumstances.

Non-federally Sponsored Projects
An individual’s membership fees in business, technical, and professional organizations may be charged to non-federally sponsored projects (excluding sponsors who cite A-122 or Uniform Guidance) as long as the benefit can be adequately articulated in the business purpose.

Unallowable Membership Dues/Fees
Membership fees or dues, such as airline, social, dining and country club dues cannot be charged directly to federal or non-federal sponsored projects.

Uniform Guidance Section: 200.413   200.454

FAQs
1. I must be a member of the association hosting the conference in order to submit an abstract or paper. Can this be direct charged to the federal award that supported the research?  Unless you have prior written approval from the agency, individual memberships cannot be direct charged to a federal award and are considered an indirect cost.  They must be charged to an appropriate non-sponsored account.

2. If I become a member of the association hosting the conference, I get a cheaper conference fee; in fact, the combined membership fee  plus the member-conference fee is less than the non-member conference  fee.  Since I’m saving the government money, can I charge this  membership fee to the federal award that supported the research?  While this sounds logical, unless you have prior written approval from the agency, individual memberships cannot be direct charged to a federal award and are considered an indirect cost.  They must be charged to an appropriate non-sponsored account.

 

PUBLICATION COSTS                                                                                                                                                                                                                                                                         Updated: 09/01/2015 The Uniform Guidance allows publication costs to be charged to the award during the close out period.  MBL needs adequate time to close awards, therefore, publication costs may be charged during the period of performance and subsequently, during the first 60 days following the end date of the federally sponsored project.

  1.  Publication costs for electronic and print media, including distribution, promotion, and general handling are allowable.  If these costs are not identifiable with a particular cost objective, they should be allocated as indirect costs to all benefiting activities of the non-Federal entity.
  2. Page charges for professional journal publications are allowable where:
    (a) the publications report work supported by the Federal Government; and
    (b) the charges are levied impartially on all items published by the journal, whether or not under a Federal award;
    (c) the non-Federal entity may charge the Federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of
    performance of the Federal award.

Uniform Guidance Section: 200.461