January 29, 2004 (Updated 12/26/2014)
The purpose of this guidance is to clarify the eligibility of FHWA State planning and research (SPR) and metropolitan planning (PL) funds for travel and training. This is in response to several inquiries about use of SPR and PL funds for attendance at AASHTO meetings, the annual bicycle/pedestrian coordinators meetings, the National Alliance of Highway Beautification Agencies, "technology transfer" activities, etc.
There are 2 aspects to consider for a cost to be charged to any Federal funds. First, is the proposed activity, project, etc, eligible for the category of Federal funds? Second, is the cost allowable to be billed the Federal funds under OMB cost principles?
Attachment A "highlights" key words from section 505 of Title 23, United States Code, Highways, to provide guidance on what activities are eligible for SPR funds. If an activity is eligible and is being funded with SPR funds, then you need to look to 2 CFR 200 - Subpart E, Cost Principles to determine if the cost (e.g., travel, training, salaries, equipment, etc.) is necessary and reasonable to perform the SPR funded work. In addition, you need to determine if the cost is allowable to be charged to the Federal funds either, as a direct or indirect charge. Attachment C includes examples of travel or training that may or may not be charged to SPR funds. Attachment D provides further guidance on use of SPR funds for technology transfer related travel.
These same criteria would apply to other categories of FHWA funds (such STP and PL funds). However, in the case of PL funds, there is no list of eligible activities in the legislation; therefore, you need to determine if a proposed activity (e.g., collection of travel data, citizen participation, development of plans and programs, etc.) is necessary to carry out the metropolitan planning process required by 23 USC 134. If it is, then the cost of travel or training that is reasonable and necessary to perform that eligible work may be charged to PL funds.
In short, travel or training for an employee who is working on an eligible SPR funded activity may be billed to SPR funds at the Federal matching ratio if the travel or training is necessary for performance of the SPR funded work and the cost is reasonable.
If you have any questions on this guidance or need assistance in determining if a cost is eligible for SPR or PL funds, you may contact the FHWA planning or research staff in the FHWA Division Office in your State or you may contact Lorrie Lau at Lorrie.Lau@dot.gov in the FHWA Office of Planning, Environment & Realty, for planning related questions or Leslie Wright at Lesile.Wright@dot.gov in the FHWA Office of Research, Development, and Technology, for RD&T related questions.
The following activities are eligible for SPR funds based on 23 U.S.C. 505, State planning and research. Component activities (e.g., traffic counting for transportation planning) necessary to perform these eligible purposes are also eligible even though not specifically listed:
Engineering surveys and investigations
Economic surveys and investigations
Planning of future highway programs
Planning of future local public transportation systems
Planning of the financing of future highway programs and local public transportation systems
Metropolitan and statewide planning under sections 134 and 135.
Studies of the economy, safety, and convenience of surface transportation systems
Studies of the desirable regulation and equitable taxation of surface transportation systems
Research, development, and technology transfer activities necessary in connection with the planning, design, construction, management, and maintenance of highway, public transportation, and intermodal transportation systems.
Study, research, and training on engineering standards and construction materials for highway, public transportation, and intermodal transportation systems
Study, research, and training on evaluation and accreditation of inspection and testing materials for highway, public transportation, and intermodal transportation systems
Study, research, and training on the regulation and taxation of highway, public transportation, and intermodal transportation systems
The conduct of activities relating to the planning of real-time monitoring elements
The provisions of 2 CFR 200 - Subpart E apply to the Federal-aid highway program. This regulation establishes the cost principles and provides guidelines for the types of costs that are allowed to be charged to a Federal grant (i.e., Federal-aid project). The regulation includes general allowability criteria as well as information on specific items of cost that are allowed and unallowed to be billed to Federal funds.
Among the general criteria for a cost to be charged to a Federal-aid project are, that it:
Travel, training, and attendance at meetings and conferences (when the primary purpose of the meeting or conference is the dissemination of technical information vs. general meetings such as the annual AASHTO meeting) are allowable if such costs meet the general criteria specified above. It must be emphasized that the employee who is attending the meeting or training must be working on the Federal-aid project, the cost must be reasonable, and the travel or training must be necessary to perform the Federally funded work. If these eligibility and allowable cost criteria are met, the costs may be billed at the Federal matching ratio directly to the Federal-aid project, which under the cost principle circulars is a cost objective. State or locally funded work (even if related to the Federal award) is a separate cost objective and the costs of travel, training and attendance at meetings and conferences by employees working on State or locally funded projects must charged to State or local funds since the costs are not incurred for the Federal award, are not allocable to the Federal award, and must be billed directly to the State or local funds to meet the requirement for consistent treatment.
Salaries, travel, etc., of supervisory employees (e.g., Chief Engineer, chief state planner or research engineer, etc.) who are not actually working on the Federal-aid project are considered to be administrative/indirect costs that may be added to the project costs of work performed by the State employees through use of an approved indirect cost rate.
Note: See attachment D for further guidance on use of SPR Funds for technology transfer related travel.
Technology transfer means those activities that lead to the adoption of a new technique or product by users and involves dissemination, demonstration, training, and other activities that lead to eventual innovation.
State DOTs are encouraged to include in their SPR work program technology transfer programs to share the results of their own research efforts and promote the use of new technology.
Sometimes, technology transfer activities can be included within the scope of individual SPR funded research projects. In such cases, travel costs incurred as part of the technology transfer activity (for instance, presenting the results of the study at a meeting or conference) should be included in the study budget and may then be charged to that study.
In many cases, however, technology transfer activities are designed as stand-alone projects to promote a technology or technique that has resulted from research performed by others or has been successfully demonstrated in another State. These activities need to be clearly defined and included in the State's SPR work program and approved by FHWA. The travel must be integral to the technology transfer function, e.g., travel to give a demonstration, conduct training, or disseminate the results of a study to a specific audience. It is inappropriate to use SPR funds under a technology transfer line item for travel to a general meeting, or even a meeting of a technical nature, unless the purpose is to conduct an previously approved SPR technology transfer activity or present the results of a completed SPR funded research study that is no longer included in the work program.
In addition as specified in 23 CFR part 420, subpart B, State DOT's are required to conduct peer exchanges of their RD&T management process on a periodic basis. Travel and other costs associated with the State DOT's peer exchange may be identified as a line item in the State DOT's work program and will be eligible for 100 percent SPR funding. The peer exchange team must prepare a written report of the exchange.