Advertising, Recruiting, Relocation Costs for a Program Director

[Jay Delaney]

I am working with a department research tech, (PI), that has a cooperative agreement where multiple federal sponsors have provided funding.  Currently there are grants from NSF, NASA, and USDA.  There is not a primary center grant in this agreement and grants come and go as they support various aspects of the mission of the center.  The PI and his team are in the process of advertising for a center director.  We are aware that advertising, travel costs and potentially relocation costs to recruit a director are allowable charges to a federal sponsored project.  However, the allocation is dicey when grants are coming and going.  Right now, advertising costs have been incurred for a program director.  PI wants these costs allocated to the two NSF grants, and the NASA grant and no allocation on the USDA grant.  Wrong!  Must allocate evenly across all grants, unless there is a valid business reason for some other prorated allocation, such as following a payroll distribution plan.  However, one of the NSF grants ends April 30, 2023, the NASA grant ends June 30, 2023, and a No Cost Extension is in process, the USDA grant ends October 31, 2023, and the other NSF grant ends August 31, 2024.  Uniform Guidance § 200.463 Recruiting costs. states, "....travel costs of applicants for interviews for prospective employment, and relocation costs incurred incident to recruitment of new employees, are allowable to the extent that such costs are incurred pursuant to the non-Federal entity's standard recruitment program."  What exactly does "to the extent that such costs are incurred pursuant to the non-Federal entity's standard recruitment program," mean?  Generally, we can give the new hire an equivalent to 1 month's salary for relocation costs, but other than that, it doesn't address charging a sponsored project at the final hour.  The only thing I can find is in the Procedure for Charging Direct Costs to Sponsored Projects.  Procedure | Charging Direct Costs to Sponsored Projects (umn.edu).  

"Allocable: A cost is allocable to a particular sponsored project or other cost objective if the goods and services involved are chargeable or assignable to that sponsored project or cost objective in accordance with relative benefits received."  Since there does not seem to be any text or wording about charging a sponsored project at the end of its life, the only thing I can communicate to the PI is that the advertising costs he wants to allocate to the NSF project that is ending April 30, 2023, are not "Allocable" because they will not provide a benefit to that project since there will not be anyone hired by then.  

What do other CAs think?  Agree?  Do not agree?  If not, Why?

Thank you,

Jay