Training and Employee Development

[Andrew Carlson]

My understanding is that much of the Department of Energy (DOE) grant guidelines and cost principles are deferred to Uniform Guidance (UG). The DOE site does not have robust agency specific literature about their program guidelines and cost principles, unlike NIH and NSF. 2 CFR 200.472 of UG states, "The cost of training and education provided for employee development is allowable." A recent reimbursement routed to me for review/approval where the grad RA traveler's business purpose is related to employee development (training) rather than disseminating information related to their direct grant research. The justification provided is as follows:

"I learned cutting-edge researches such as machine learning approaches and computational screening to compute gas storage and separation capacities of materials. This helps my project with screening of porous materials for gas storage and separations." [SIC]

1) Would you allow this travel expense on a DOE grant?

2) In general, how are people determining the allowability of employee development (training) on grants?

When broadly held up to the general accounting cost principles, I know that employee development and training is difficult to justify on sponsored grants.

A) Reasonableness: I think the provided justification passes this first test.

B) Allocability: Hard to argue that this expense even remotely meets this test. The benefit cannot be directly applied to the DOE grant. There's also an argument to be made that this knowledge was not necessary, as the original proposal was submitted with the expectation that the aims could be achieved without the new research field findings.

C) Consistently treated: Kind of the heart of this post. The expectation is that the expense activity would fail this test. I assume the vast majority of accountants would not allow this employee development expense to be on a grant.

D) Allowable: I would argue that it does pass this final test. Specific grant terms do not prohibit the expense activity and I interpret UG as allowing it. However, failing the other tests tells me I should not put this on the grant.

3) How do other Certified Approvers interpret and apply 2 CFR 200.472? ("The cost of training and education provided for employee development is allowable.")

Thanks to everyone who looks at this. Best!