Allowable Costs

Allowable Costs

Cost Principles: Allowable and Unallowable Costs

The following list is for general purposes only. All costs applied to sponsored research accounts should pass the test of being reasonable, allowable, allocable, and consistently treated.

Allowable expenses are reasonable and necessary, allocable to sponsored projects, given consistent treatment and conform to any limitations or exclusions set forth in the relevant federal regulations (if applicable), the sponsored agreement and the University policy.

An expense is allocable if it is incurred solely to advance the work under the agreement or if it benefits both the sponsored agreement and other work of the institution, in proportions that can be approximated through use of reasonable method.

A reasonable cost is one that a prudent person would have incurred under the circumstances prevailing when the purchase was made.

Be consistently treated. Costs incurred for the same purpose, in like circumstances, must be treated consistently as either a direct or indirect (F&A) costs.

Further guidance is found in 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.

Item

Description

Alcoholic Beverages

unallowable as an entertainment expense. 

Administrative and Clerical Salaries

Previously unallowable under OMB A-21 but under Uniform Administrative Cost Principles, allowablewith the satisfactory explanation the costs are integral to the project. 

Advertising

Allowable for recruitment of staff trainees, or research subjects, procurement of goods and services and other expenses when necessary to meet grant requirements. 

Animals

allowable for acquisition, care and use of experimental animals, contingent up compliance with applicable principles of PHS Policy on Humane Care and Use of Laboratory Animals

Audit Costs

allowable when audit’s scope is limited to a single NIH grant-supported project otherwise should be treated as indirect cost. 

Bad Debts

unallowable 

Books and Periodicals

allowable as a direct costs when required for the conduct of the project but where an institution has a library such costs are normally treated as indirect costs. 

Compensation of students

Tuition remission and other forms of compensation paid as, or in lieu of wages performing work are allowable provided that: 

  • There is a bona fide employer / employee relationship between the student and the university.
  • Tuition or other payments are reasonable compensation for the work performed and conditioned on the performance of necessary work. 
  • It is the institution’s practice to similarly compensate students in non-sponsored activities as well as sponsored activities. 

Consultancy

unallowable by DSU faculty unless across department lines or at a distant and remote location. allowable when the person is retained to provide professional services for a fee but not an employee. 

Entertainment Costs

unallowable. This includes the cost of amusements, social activities, and related incidental costs. 

Fundraising

unallowable 

Honoraria

unallowable when the primary intent is to confer distinction on, or to symbolize respect, esteem, or admiration for, the recipient of the honorarium. A payment for services rendered, such as a speaker’s fee under a conference grant, is allowable 

Invention, Patent, or Licensing Costs

unallowable as a direct cost unless specifically authorized in the Notice of Award. May be allowable as indirect costs provided they are authorized under applicable cost principles and are included in the negotiation of indirect cost rates. Such costs include licensing or option fees, attorney’s fees for preparing or submitting patent applications, and fees paid to the U.S. Patent and Trademark Office for patent application, patent maintenance, or recordation of patent-related information. 

Lobbying

Generally unallowable, including costs of lobbying activities to influence the introduction, enactment, or modification of legislation by the U.S. Congress or a State legislature. Under certain circumstances, as provided in the applicable cost principles, costs associated with activities that might otherwise be considered “lobbying” that are directly related to the performance of a grant may be allowable. The recipient should obtain an advance understanding with the GMS if it intends to engage in these activities. 

Losses

unallowable to cover an over-expenditure on one grant by using funds from another. 

Meals

Generally unallowable except for the following: • Subjects and patients under study • Where specifically approved as part of the project or program activity, e.g., in programs providing children’s services • When an organization customarily provides meals to employees working beyond the normal workday, as a part of a formal compensation arrangement • As part of a per diem or subsistence allowance provided in conjunction with allowable travel. Under a conference grant, when meals are a necessary and integral part of a conference, provided that meal costs are not duplicated in participants’ per diem or subsistence allowances. 

Guest meals are not allowable. (See “Consumer/Provider Board Participation” in the HHS GPS regarding the allowability of the cost of meals for consumer and provider board participants in grant-supported activities.) 

Office Supplies

unallowable: Normally a part of indirect costs. 

Pre-award costs

Costs incurred prior to the effective date of the sponsored agreement, whether or not they would have been allowable thereunder if incurred after such date, are unallowable unless approved by the sponsoring agency or authorized under expanded authority. Where authorized by the sponsoring agency as an expanded authority, a recipient may, at its own risk and without sponsoring agency prior approval, incur obligations and expenditures to cover costs up to (and including) 90 days before the beginning date of the initial budget period of a new or competing continuation award if such costs • are necessary to conduct the project or program, and • would be allowable under the grant, if awarded. However, even if authorized as an expanded authority, if a specific expenditure would otherwise require prior approval, the cost or activity must meet the same tests of allowability as if incurred after award. 

If not authorized as part of expanded authorities, the applicant/recipient must seek sponsoring agency prior approval before incurring pre-award costs. Sponsoring agency prior approval is required for any costs to be incurred more than 90 days before the beginning date of the initial budget period of a new or competing continuation award. 

Proposal Costs

unallowable including payroll for personnel working on a proposal. 

Promotional Items (SWAG)

Promotional items and memorabilia (SWAG e.g., pencils, cups, t-shirts, cookbooks, bags, etc.), gifts, and souvenirs designed to promote the recipient’s organization are unallowable as advertising/public relations costs. 

Trainee Costs

Allowable under training grants if permitted by authorizing statute or governing programmatic regulations. Institutions may re-budget funds into or within trainee cost categories (stipends, tuition and fees including medical insurance) but may not re-budget funds awarded for trainee costs into another budget category without prior sponsor approval. 

Travel

Allowable as a direct cost when the travel benefits the project and follow institutional policy. When travelling by air, economy class should be used. Foreign travel must be specifically authorized by the awarding agency and must comply with Fly America Act.