December 8, 2006
Question: Under what circumstances may the cost of conferences or other meetings be billed to FHWA planning and research funds, including metropolitan planning (PL), State Planning & Research, and other FHWA program funds that can be used for planning or research?
Answer: In order for any cost to be billed to Federal funds, the cost: (1) must be incurred for an activity that is eligible for the category of funds being used (e.g., PL funds can only be used for eligible metropolitan planning related activities); and (2) must be allowable under the Office of Management and Budget's (OMB) cost principles for the type of agency that incurs the cost. One of the basic OMB guidelines for allowability of a cost is that the cost be necessary and reasonable "for proper and efficient performance and administration" of the Federal awards" (i.e., Federal grant, project, etc.). The OMB cost principle circulars indicate that the cost o f conferences or other meetings may be allowable for reimbursement when the primary purpose is the dissemination of "technical information."
In the case of the use of FHWA planning and research funds, the term "technical" should not be construed narrowly to mean just "science" activities such as research, travel modeling, etc. For example, a meeting or conference where information is presented on metropolitan planning process legislation and/or regulations would be allowable for PL funding if the attendance of MPO staff was deemed necessary, and the cost reasonable, for that staff to better perform metropolitan planning.
Below are some "examples" of meetings and conferences that may be appropriate to charge to FHWA planning and research funds as a direct or indirect cost:
Example 1: An MPO staff agency hosts a conference on visualization techniques in metropolitan planning for local agency staff and citizens, with presentations by invited speakers. Since the use of visualization techniques in the metropolitan planning process is required and the conference will enhance the MPO's performance of the planning process, all reasonable costs (e.g., room rental or speaker travel/fees) associated with the conference may be billed directly to PL funds.
Example 2: Staff who are working on the Federally funded metropolitan or statewide transportation planning process travel to attend a conference where the primary purpose is to present information on new/revised planning requirements. The travel costs, including meals and lodging, and any registration fees may be billed directly to the Federal funds.
Example 3: MPO policy board members travel to attend a seminar where the primary purpose is to enhance their knowledge of the metropolitan planning requirements so that they may more effectively perform their duties. The travel costs, including meals and lodging, and any registration fees may be billed directly to the Federal funds.
Example 4: A national organization's annual conference includes sessions on a wide range of topics with a few sessions on transportation planning and "social activities/entertainment" (e.g., outings, golfing, etc.). Since attendance at the majority of the conference sessions is not necessary for the performance of the transportation planning process, the costs should be treated as indirect and not billed directly to FHWA planning funds; or the costs may be prorated in proportion to the conference that is related to the planning process. However, any costs associated with entertainment (e.g., extra days lodging, fees, etc.) may not be billed either as a direct or indirect cost since entertainment costs are not allowable under OMB cost principles.
Albeit not all-inclusive, the above "examples" are intended to provide an illustration of the types of "conference or meeting" that may or may not be eligible for FHWA planning and research funds. It also must be kept in mind that the above guidance is based on Federal guidelines and that what is allowable under State law or procedures must be considered. Additional guidance, originally issued in 2004 jointly with the Office Research, Development & Technology, is available online at http://www.fhwa.dot.gov/hep/guidance/sprt.cfm.