Question from the DSE: If T-shirts are purchased for the attendees of a youth event (11 t-shirts altogether) and they aren’t souvenirs, are they allowable? I’m looking at uniform guidance trying to decide, I initially denied it but rethinking things.
Answer: My typical answer to all questions related to allowability is, “It depends.” This is a great example of how the use of the item, and not the item itself, determines its category and therefore its allowability. Promo giveaways and souvenirs are not typically allowed. Advertising (except for job openings) is not typically allowed. However, outreach is allowed (and required, actually, to your identified unserved or underserved groups). As a result the expenses that are considered to be essential to accomplishing the tasks of the grant project are allowable. An argument can be made that T-shirts are essential when a group from around the state gets together for an outreach or advocacy event, for example. That way the participants know each other to be part of the same group and the strength in the numbers of the advocates has an impact. Giveaways that draw people to a table where they sign in can become the basis for outreach to youth. Pens with the center’s name and number on them and business cards and brochures can all be classified as outreach materials.
If the CIL can justify that the purchase was essential in outreach, advocacy or some other project of its grant, it should be allowed.
Please note the word essential. Every purchase you make with federal grant dollars is required to be reasonable (a good price), necessary, allowable and allocatable.
For your reference, the regulations contain a list of selected items of cost that may not be allowable. They are alphabetical and you can find them following the intro here: https://ecfr.io/Title-45/pt45.1.75#se45.1.75_1420
Do notice that language makes a difference. For example, Centers are required, and Statewide Independent Living Councils are allowed (if addressed in SPIL) to do resource development. Like outreach, if you categorize an expense as advertising or public relations or fund raising then the expense may be unallowable. If you categorize it properly and show it is reasonable and necessary as resource development, it should be alllowed.