I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder 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 CU Boulder Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
II. Definitions
CU Boulder 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 (CU Boulder)
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.
III. Procedures
A. Federal Awards
Institutional
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. While the Uniform Guidance allows institutional memberships and subscriptions, it is extremely difficult to allocate an institutional membership or subscription directly to a particular sponsored project. Therefore, it is CU Boulder’s position that institutional memberships and subscriptions may not be charged to federal awards. It is also CU Boulder’s position that sponsor approval is required prior to charging professional activity costs to a federal award.
Individual
Individual memberships are treated as indirect costs per 2 CFR 200 Appendix III.B.6.b.(2). The exception for individual memberships is when CU Boulder receives an award with an institutional allowance, and the federal agency specifically allows direct charging of individual dues, or memberships, or subscriptions. In these cases, memberships, subscriptions, and professional activity costs may be charged directly to a sponsored project. 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.
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, CU Boulder’s Cost Principles Policy and related 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.
C. Process
At Proposal
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
Typically, when CU Boulder receives an institutional allowance, it is coded to account code 460000 - Operating Expenses General Budget in the finance system. 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.
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 grant accountant to document the necessity and benefit of the cost. If sponsor approval is required, the OCG grant officer or contract officer 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 department and in Boulder eRA (BeRA) for future reference should the expenditure be questioned at a later date.