First in planning the event and selecting the meal to be served every effort should be made to have a margin between the planned meal cost and the allowable per-diem. This will allow some cushion for no-shows before the per-diem is exceeded. If however the per-diem per participant is exceeded and the amount is reasonable under the circumstances we would consider the additional cost allowable. There is still a possibility that an auditor would disagree and deem the excess over per-diem unallowable.

Yes, this will provide good supporting documentation for the number of people that the meal cost covered (determine the cost per participant).

Yes, this would provide good supporting documentation to demonstrate that there was a business purpose for the meal and that it is not a social event.

No, coffee service and other drinks for breaks can be treated as incidental and not included in individual per diem.

GCA no longer applies the food flag to sponsored Awards/budgets. Departments are responsible for knowing if food (this particular event) was included in the proposal or that written sponsor approval has been obtained. You should only need to fill out the meal form once.

This depends on the sponsor and the terms and conditions applicable to the award. Some sponsors do not allow meal costs for employees of the institution if they are not in travel status. If they are attending the workshop and are approved by the sponsor, the sponsor's approval should be retained on file.

The cost of the dinner and how it benefits the Award should be part of the original proposal. As with all expenses, there is a requirement to show how the expense is necessary for the achievement of the award objectives. See Spending/Food for more information.


The value (cost) of the unused gift cards should be refunded to the sponsored award as the gift cards were not used.  The cost should be transferred to a non-sponsored budget.   The gift cards may then be used in accordance with the requirements of the funding source where the cost of the gift cards was transferred to.  For example, if the cost of the gift cards was transferred to a department budget, the gift cards should be used in accordance with the requirements or guidelines of the department budget.

Answer: This type of expense is not allowable. According to §2 CFR 200.434   Contributions and donations:

Costs of contributions and donations, including cash, property, and services, from the non-Federal entity to other entities, are unallowable.

It is the expectation that these funds are for the benefit of the University rather than the individual PI.  The Dean/Director/Chair has the authority to direct the use of the funds at the request of an individual PI.

Generally, accepting gifts from suppliers/vendors could be construed as creating a conflict of interest. For more information see Internal Audit's ethics page.

Information on discretionary budgets can be found here on the GCA website and here.

Intellectual Property

Assuming this a federal grant, 2 CFR 200.448 Intellectual Property which covers the allowability of patent costs, applies. The regulation does not makes a distinction for provisional patent, so the regulation rules would apply. Basically if title to the Patent or a Royalty-free license is required to be conveyed to the Federal Government the cost would be allowable when a provisional patent is required in order to secure the final patent. If title or royalty-free license is not required by the federal award then the cost would not be allowable.


In most cases the UW allows donated leave to be charged to a sponsored Award. UW policy allows shared leave and consistently charges it to the budget(s) from which the leave donor is being paid at the time of the donation, regardless of the funding source.  However, some caution and judgement is required to ensure that the charge for the shared leave is reasonable and does not impact the ability to complete the requirements of the Award. If there is an impact to the scope or objectives of the Award, then sponsor approval would be required.


As the benefit to this membership can be received by any number of Awards, the cost cannot be attributed to a single Award.  The cost of membership should be billed to either department funds or a discretionary budget.

Federal regulations allow the cost of the institution's membership in business, technical, and professional organizations as part of F&A, but do not mention individual memberships.  Per GIM23, individual memberships are allowable only as an indirect cost. This is because professional memberships benefit the staff in all of their professional work; the cost cannot benefit just a single Award. Thus, the cost cannot be included on an Award budget. As the nature of a membership in one of these organizations provides a benefit to all the work and professional activities of the individual, it is difficult to allocate the cost of this benefit to a single Award. For this reason individual memberships are not allowable as a direct cost to an Award.

Institutional subscriptions may be allowable when directly related to the objectives of a sponsored Award. An example of an allowable direct charge of an institutional subscription would be where the objective is to compile data from articles into a database, or as reference material to support the Award. Per GIM 23, individual memberships and subscriptions are allowable only as an indirect cost. This is because professional memberships and subscriptions benefit the staff in all of their professional work; the cost cannot benefit just a single Award. Thus, the cost cannot be included on an Award budget.

No Cost Extension

Federal agencies have different requirements.  Some agencies may require the same level of effort as was proposed during the original term of the award and others not.  For instance NIH currently only requires a “measurable” level of effort for the PI and other key personnel during the term of the award including any NCE periods.  NSF takes a different view and assumes that the originally proposed effort will be spread over the entire award period including any NCE periods.  We recommend that the best practice is to follow sponsor specific terms and conditions, which may include any FAQs. 

In the absence of any guidance from the sponsor, if committed faculty effort will be reduced 25% or more during the extension period, a request for approval to reduce faculty effort should be submitted to the sponsor at the same time as the NCE request or notification.  If no mention is made of a faculty effort reduction during the NCE then there is an expectation that the effort remains at the same level as committed during the original award period.

Links to information from NIH and NSF follow:

Project End Dates

This is a question of “allocability”. Does the contract deliverable provide a direct benefit to the sponsored award over the entire life of the contract?  For contracts that extend beyond the end date of an award the cost should be allocated on a reasonable basis.  Typically the basis is the number of months the award is active during the life of the contract.  Once the award ends the contract is no longer providing a benefit to it so that portion of the contract cost is not allocable. 

Proposal Costs

The costs of preparing bids, proposals, or applications for the receipt of any new funding is generally unallowable as a direct cost on an existing award. This includes proposal costs for a new award, a competing segment of an existing program, or for supplemental funding on an existing award.

The reason why proposal costs for the receipt of new funding is unallowable is because any costs charged to an Award must provide benefit to that Award.  It is difficult to justify how the expenditure of effort for new funding is of benefit to the existing Award (i.e., how does effort spent on obtaining additional funding provide benefit to the objectives of the existing award?).

Costs related to the receipt of funding for a non-competing segment of an existing award are allowable. This is because these funds are not considered new funding since they are identified in the award.  Also, under NIH Mentored Career Development (CDA or mentored “K”) awards it is allowable for effort devoted to proposal preparation costs for subsequent research support to be direct charged.  This activity can be considered part of the awarded effort commitment.

Publication Costs

In accordance with 2 CFR 200.461, the federal government states that “publication costs” includes “costs for electronic and print media, including distribution, promotion, and general handling are allowable” as a direct cost when identifiable with a particular award.  

Page charges for professional journal publications are also allowable when: 1) the publication reports on the work supported by the award, and 2) the publisher charges the same costs for all items published.  These costs may be incurred after the end date of the award (Total Period End Date) but before award close out.  This means that the costs must be posted to the award (paid) by the Final Action Date (FAD) in order for the cost to be included with the final invoicing/reporting.  If it is anticipated that publication costs will need to be paid after the FAD, then a No-Cost Extension (NCE) must be obtained or requested of the federal sponsor.

As with any type of cost, an estimated amount of anticipated publication costs may not be added to the final invoice/financial report to allow for costs to be incurred after the FAD.  

Report Costs

Grant writing and report costs that are required as part of the terms of the Award are allowable. For example, progress reports, annual reports, and/or technical reports are required and therefore, would be allowable. Proposal costs, however, would not be an allowable expense. See the FAQ on Proposal Costs.