Memberships, Subscriptions and Professional Activity Costs Policy for Federally Sponsored Programs

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It is the policy of New York University (NYU, “the University”) that generally membership dues, subscriptions and professional activity costs may not be charged directly to Federally sponsored projects or as cost sharing unless noted by the sponsor; these costs are normally paid through NYU’s Facilities & Administrative cost rate. This policy is in accordance with Federally approved cost accounting practices and Federal regulations outlined in the Federal Office of Budget and Management (OMB) Circular A-21, Cost Principles for Higher Educational Institutions (http://www.whitehouse.gov/omb/circulars_a021_2004/).

Purpose of this Policy

The purpose of this policy is to provide guidance for charging membership dues, subscriptions and professional activity costs in accordance with Federal regulations, OMB Circular A-21 Cost Principles for Higher Educational Institutions, § J.33 Memberships.

Scope of this Policy

This policy is applicable to all schools, departments, units and personnel of the University involved in administering sponsored awards.

Procedures for Implementation

Payments for individual and institutional membership dues and subscriptions generally should be charged to unrestricted accounts (non-sponsored projects such as discretionary chartfield incentive accounts, startup funds and endowments). If these accounts are not available, researchers should contact the Dean’s office for alternative funding to support these types of costs.
The cost of individual memberships or subscriptions is allowable when fully justified in sponsored-approved grant applications and contract proposals. The circumstances under which such costs may be allowable include, but are not limited to:

  • Required for attendance at conference;
  • Required for participation as guest speaker at a conference or symposium;
  • Required to distribute technical information or to publish research results.

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Federal Regulations

  1. Dates of official enactment and amendments: Sep 1, 2013
  2. History: blank
  3. Cross References: blank