I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder regarding the use of funds from sponsored projects for recruiting costs 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.
Recruitment costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.463 as:
Costs of “help wanted” advertising, operating costs of an employment office necessary to secure and maintain adequate staff, costs of operating an aptitude and educational testing program, travel costs of employees while engaged in recruiting personnel, travel costs of applicants for interviews for prospective employment, and relocation costs incurred incident to the recruitment of new employees.
A. Federal Awards
Under the guidelines imposed by the Uniform Guidance, recruiting costs may be considered allowable direct charges, provided that the size of the staff recruited and maintained is in keeping with workload requirements. CU Boulder considers recruitment costs to be allowable on sponsored projects if the position they are recruiting for is essential and allocable to the performance of the award.
Recruiting is considered necessary when there is a need for a specialized individual with unique skills and expertise in order to complete the scope of work of the project, and there are no available faculty or staff currently employed within the unit who could perform the same tasks. Eligibility is limited to research faculty, associates, and post docs. GRAs are generally not considered essential personnel, so direct charging of recruiting costs to a sponsored project for a GRA is allowable only in exceptional cases.
Recruiting costs are considered allocable when incurred solely to advance the research objective of the award. If the personnel being recruited will not be working on the sponsored project full time, only the proportionate amount of the recruiting costs should be allocated to the sponsored project.
Special salary payments, fringe benefits, and salary allowances incurred to attract professional personnel that do not meet the test of reasonableness, or do not conform to CU’s recruiting practices, are unallowable. Relocation costs (2 CFR §200.464) are allowable when incurred incident to recruitment of a new employee under certain circumstances. Please refer to the Procedural Statement for Relocation Costs for further guidance on relocation costs.
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 charging personnel recruitment 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 personnel recruitment 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.
Recruiting costs should be identified in the proposal budget justification, and justified as to how 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 recruiting costs. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
In the case of international recruitment:
After an Award is Funded
Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted recruiting cost is required after an award is funded, the department should work directly with the assigned grant accountant to ensure this cost is properly documented prior to the costs being incurred. The need for recruiting for a specific project, and how it is necessary and allocable, should be fully described in the justification and retained by the department for future reference should the expenditure be questioned at a later date.
D. Related Procedural Statements, Forms, Policies & Tools
If the candidate is being recruited to work on a sponsored project, the candidate’s meal would be an allowable cost as part of their travel expenses, either as a direct reimbursement or as a per diem charge. The PI and colleagues’ meal would not be an allowable expense because they are not in travel status.
Recruiting costs are not considered marketing costs and should be included under Other Direct Costs: Recruiting Costs.
It depends. Please review your award documents and sponsor guidelines, and contact your grant or contract officer for assistance. In general, if prior approval is required for international travel, prior approval will be required for international travel associated with recruiting.
If the cost of the airfare is going to be charged to a federally funded sponsored project that the candidate would potentially be working on, the air travel needs to comply with the Fly America Act even if the candidate will be purchasing the ticket and getting reimbursed for its cost.
Yes, costs of a recruitment search are allowable, even if the position ultimately is not filled.