Program outreach allowable costs vs. promotional items

[Carolyn O'Grady]

Hi CAs,

I have a question relating to one of the NSF-funded centers I support. They would like to order some program materials to support the work of the ERC such as branded folders, t-shirts, stickers, and lunch totes.

These items would be designed to promote team-building, create a sense of community, and develop Center culture among center program participants (REU, Teacher Prof. Development Workshop, High School Internship Program, Scholar Leadership Council, etc.). These would be used for meetings, events, summer programs, and as giveaways at the State Fair.

Would these costs be allowable on the grant? UG 200.421 states that program outreach is allowable, but that promotional and PR items are unallowable. I could see it both ways so I thought I'd ask this group. Thanks!

§ 200.421 Advertising and public relations.

(a) The term advertising costs means the costs of advertising media and corollary administrative costs. Advertising media include magazines, newspapers, radio and television, direct mail, exhibits, electronic or computer transmittals, and the like.

(b) The only allowable advertising costs are those which are solely for:

(1) The recruitment of personnel required by the non-Federal entity for performance of a Federal award (See also § 200.463);

(2) The procurement of goods and services for the performance of a Federal award;

(3) The disposal of scrap or surplus materials acquired in the performance of a Federal award except when non-Federal entities are reimbursed for disposal costs at a predetermined amount; or

(4) Program outreach and other specific purposes necessary to meet the requirements of the Federal award.

Unallowable advertising and public relations costs include the following:

(1) All advertising and public relations costs other than as specified in paragraphs (b) and (d) of this section;

(2) Costs of meetings, conventions, convocations, or other events related to other activities of the entity (see also § 200.432), including:

(i) Costs of displays, demonstrations, and exhibits;

(ii) Costs of meeting rooms, hospitality suites, and other special facilities used in conjunction with shows and other special events; and

(iii) Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, and providing briefings;

(3) Costs of promotional items and memorabilia, including models, gifts, and souvenirs;

(4) Costs of advertising and public relations designed solely to promote the non-Federal entity.

[Heather Steen]

I think item 4 is things like paying for an exhibit table at a conference to attract participants, not handing out t-shirts.  There are a number of NSF centers that take turns renting a table at a conference like  NOBCChE to promote the summer REU programs for all of the centers, and I think I've allowed that charge on the grant with outreach related justification. 

All my centers (Chemistry has one NSF and two DOE) have purchased some sort of promotional items, and all have used non-sponsored funds to do so.  In this case, I don't think you can really claim that it is necessary to have matching t-shirts to get people interested in your program