Individual Memberships, Subscriptions, and Professional Activity Costs

Purpose

This document is intended to serve as formal guidance for Western Washington University regarding the use of funds from federally sponsored projects for memberships, subscriptions, and professional activities. It builds upon WWU’s Standard on Allowable Costs.

Definitions

Memberships are fees or dues paid for an individual or an institution to join a technical, business, or professional organization for a specific length of time. Individual memberships are associated with, and provide benefits to, a single person only. Institutional memberships are associated with, and provide benefits to, an entire non-federal entity (Western Washington University).

Subscriptions are payments in exchange for receiving technical, business, or professional periodicals or access to information (ex. inter-library searches or national DNA database).

Professional activities are intended to enhance an individual’s professional development, including obtaining skills and qualifications needed to progress in one’s career.

Background

Part 200.454 of the Code of Federal Regulations allows the cost of the institution's membership, subscription, and professional activity in business, technical, and professional organizations as part of facilities and administrative costs, but does not address individual memberships. This is because memberships benefit the individual across all professional work; as the nature of a membership in one of these organizations provides a benefit to all related work of the individual, it is difficult to allocate the cost of this benefit to a single grant award. For this reason, individual memberships, subscriptions, and professional activity expenses are not allowable as a direct cost on an award.

Pre-Award:

The only time that costs for dues, memberships, subscriptions, or professional activities will be included on a federal proposal is when the sponsor specifically allows these types of costs.

To charge the above costs to a federally sponsored project, the criteria listed in 2 CRF 200.403 must be met. In addition, the following two criteria must be met during the proposal process:

  1. The costs are specifically identified with the objectives of the project or activity.
  2. The costs are explicitly listed in the University proposed and sponsor-approved budgets.

Justification for these expenses presented in a project budget could include circumstances in which:

  1. The membership creates cost-savings to attend a conference at which research results specific to the project will be presented, or whose membership is mandatory in order to present a paper specific to the project.
  2. The sole purpose of the membership is to purchase a periodical at a reduced rate, the periodical is not available through the institution’s library services, and the periodical is necessary for the sponsored project.