How can I distinguish between unallowable advertising and outreach? Can I call promotional giveaways outreach?
While advertising is one of those categories that is on the list of those not allowed with federal funds, not all advertising is unallowable. Uniform Guidance section 200.421 (HHS regulation section 75.421) confirms that advertising costs are allowable for:
- recruiting personnel necessary for the performance of a Federal award,
- procurement of goods and services for performing a Federal award,
- program, outreach, as well as
- other specific purposes necessary to meet the requirements of the Federal award.
Also, certain public relations that include communicating with the public and the press pertaining to specific activities or accomplishments resulting from performance of the Federal award are allowable.
Other public relations costs are not allowed, nor is the cost of displays, demonstrations or exhibits, or the costs of promotional items or memorabilia.
John F Heveron, Jr. Principal, Heveron and Company CPAs