Subject:  Membership Costs No.        95-5
Date:    April 27, 1995

(Note: This Important Notice is being sent to Account Managers, Chairpersons, Deans and Chancellors. Please forward to others who have a need to know.)

Effective July 1, 1994 there was a change in OMB Circular A-21 that had a direct impact on memberships being charged to federal and federal pass-through projects. This was previously stated in Important Notice 94-4 dated June 22, 1994 but continues to be a problem.

The federal regulation states that memberships shall normally be treated as indirect costs; therefore, they are unallowable to be charged to federal and federal pass-through grants as a direct cost. These memberships are considered personal in nature and should not be charged to a project. Therefore, no memberships can be charged to federal and federal pass-through grants after July 1, 1994. Membership dues are also not allowable even if they include a subscription.

On non-federal grants, memberships are allowed unless prohibited by the agency guidelines or specific award language. Justification must be included on the disbursement voucher or purchase order, to indicate how it relates to the scope of the project.