My typical answer to whether a cost is allowed is “It depends”. Remember we are talking about whether you are allowed to use federal grant funds (usually Part B and Part C funds) to pay for these things.
45 CFR §75.421 addresses advertising and public relations. It defines the term advertising costs means the costs of advertising media and corollary administrative costs. Advertising media include magazines, newspapers, radio and television, direct mail, exhibits, electronic or computer transmittals, and the like.
Advertising costs are allowed for recruiting staff, for seeking out needed goods or services, for getting rid of property acquired through the grant that is no longer of use to the grant, and most important for centers, for outreach.
Sometimes you are asked to sponsor an event — to have an add in a program for example. Ask yourself, how does this help with outreach to consumers who are unserved or underserved? If you expect the individuals reading the program to be potential consumers, then you may be able to justify the expense. Any time you have this kind of expense, it is well worth it to write out your justification and include it with the expense information. Tell why you feel this is allowable advertising rather than non-allowable.
In the same section of the regulations, the term “public relations” is defined to include community relations and any activities dedicated to maintaining the image of the non-Federal entity or maintaining or promoting understanding and favorable relations with the community or public at large or any segment of the public.
The only allowable public relations costs are costs that your grant specifically requires, costs to communicate with the public and press about the accomplishments of the grant, and public relations to keep the public informed around “matters of public concern, such as notices of funding opportunities, financial matters, etc.”
Ok, all the above may be allowable, as long as you justify how it fits into the allowed areas. Unallowable advertising and public relations costs include a list of things that federal funds specifically cannot be used for, including:
- Costs of promotional items and memorabilia, including models, gifts, and souvenirs;
- Costs of advertising and public relations designed solely to promote the non-Federal entity.Costs of meetings, conventions, convocations, or other events related to other activities of the entity (see also §75.432), including:
- Costs of conferences including the costs of displays, demonstrations, and exhibits; of meeting rooms, hospitality suites, and other special facilities used in conjunction with shows and other special events; and salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, and providing briefings.
Before you panic about whether you can attend that national conference, note that training and education costs are allowed, and that travel costs related to that training and education may be allowed if you can justify that the attendance is necessary to the one attending. Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-Federal entity. Specific to lodging and subsistence, the hotel expense is allowed if it is considered reasonable. If you tend to book a room that is more expensive than most, that cost may be questioned. In that case you have to explain why it was necessary in your financial documentation of the costs. You also must follow you own written policies around travel.
There is an expectation that you use commercial (not charter) air travel and that your cost is for not more than the least expensive unrestricted accommodations class they offer. It would not typically be allowed for you to fly first class, for example.
If you are involved in sponsoring a conference, look at 45 CFR 75.432 on conferences. A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the non-Federal entity and is necessary and reasonable for successful performance under the Federal award. Allowable conference costs paid by the non-Federal entity as a sponsor or host of the conference may include rental of facilities, speakers’ fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences unless further restricted by the terms and conditions of the Federal award. As needed, the costs of identifying, but not providing, locally available dependent-care resources are allowable. Conference hosts/sponsors must exercise discretion and judgment in ensuring that conference costs are appropriate, necessary and managed in a manner that minimizes costs to the Federal award.
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