[lstac] Allowable Cost Question

Tue Jun 20 08:08:37 PDT 2023

Ah, I understand your No then. I agree it must be a substantive educational event to qualify under the Program Participant, not a more general event or regular transportation.

Karren Reish
Library Grants Coordinator
Library of Michigan
517-241-0021 / www.mi.gov/lsta<http://www.mi.gov/lsta>

From: Erica McCormick <emccormick at tsl.texas.gov>
Sent: Friday, June 16, 2023 2:15 PM
To: Christine Gauvreau <Christine.Gauvreau at ct.gov>; Reish, Karren (MDE) <ReishK at michigan.gov>; Egan, Karen <KEgan at ILSOS.GOV>; Ratliff Warren, Dena (ELC) <dratliffwarren at ky.gov>; Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov>
Subject: RE: [lstac] Allowable Cost Question

CAUTION: This is an External email. Please send suspicious emails to abuse at michigan.gov<mailto:abuse at michigan.gov>

To all, I haven't given up. Thanks for the discussion.

I've unearthed some history on this. I found some old emails (ca 2012) referencing OMB circulars pertaining to travel for program participants and it not being allowable. Apparently, the circulars spoke directly to this. Not sure of the circular reference.

Fast forward to the current rules...the rules only speak to transportation and travel for agency employees and board members NOT program participants. As you've mentioned, the section on participant support costs pertain to conferences and training projects paid to or on behalf of participants and trainees to attend the conference or training.

I'm not yet ready to consider educational classes as training or renting a bus to get them there as a participant cost. Most of the requests we've had involve transporting students to an event or after-hours care which would not be allowable. What I read below is providing a service for participants to get them there; it is not a travel stipend or scholarship for travel. Because of the inconsistencies and potential headaches, we will continue to disallow it for now. But I can see continuing the discussion on it.

As you've all said, when in doubt check with your program officer, but it would be nice to have a definitive consistent decision from IMLS.

Thanks for reading,
Erica

From: Christine Gauvreau <Christine.Gauvreau at ct.gov<mailto:Christine.Gauvreau at ct.gov>>
Sent: Thursday, June 15, 2023 12:56 PM
To: 'Reish, Karren (MDE)' <ReishK at michigan.gov<mailto:ReishK at michigan.gov>>; Egan, Karen <KEgan at ILSOS.GOV<mailto:KEgan at ILSOS.GOV>>; Erica McCormick <emccormick at tsl.texas.gov<mailto:emccormick at tsl.texas.gov>>; Ratliff Warren, Dena (ELC) <dratliffwarren at ky.gov<mailto:dratliffwarren at ky.gov>>; Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: RE: [lstac] Allowable Cost Question

Especially organized transportation for LSTA funded programs/project is something we fund.

Best,
Chris
(she, her, hers)

Christine Gauvreau|E-Rate Coordinator|LSTA Grants Coordinator|Digital Inclusion Consultant
Middletown Library Service Center
Christine.Gauvreau at ct.gov<mailto:Christine.Gauvreau at ct.gov> | Office: (860) 704-2224
https://ctstatelibrary.org<https://ctstatelibrary.org/>

[cid:image001.png at 01D9A367.90F69B60]

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Reish, Karren (MDE) via lstac
Sent: Thursday, June 15, 2023 1:47 PM
To: Egan, Karen <KEgan at ILSOS.GOV<mailto:KEgan at ILSOS.GOV>>; 'Erica McCormick' <emccormick at tsl.texas.gov<mailto:emccormick at tsl.texas.gov>>; Ratliff Warren, Dena (ELC) <dratliffwarren at ky.gov<mailto:dratliffwarren at ky.gov>>; Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: Re: [lstac] Allowable Cost Question

EXTERNAL EMAIL: This email originated from outside of the organization. Do not click any links or open any attachments unless you trust the sender and know the content is safe.
I would agree with Karen, but I would expect this to be an established group of participants having transportation to a specific event vs. general transportation to the library that can include attending the ELL class.

Karren Reish
Library Grants Coordinator
Library of Michigan
517-241-0021 / www.mi.gov/lsta<http://www.mi.gov/lsta>

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Egan, Karen via lstac
Sent: Thursday, June 15, 2023 12:58 PM
To: 'Erica McCormick' <emccormick at tsl.texas.gov<mailto:emccormick at tsl.texas.gov>>; Ratliff Warren, Dena (ELC) <dratliffwarren at ky.gov<mailto:dratliffwarren at ky.gov>>; Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: Re: [lstac] Allowable Cost Question

CAUTION: This is an External email. Please send suspicious emails to abuse at michigan.gov<mailto:abuse at michigan.gov>

Hi Dena,

Illinois would probably allow this expense because it supports the ELL learners participating in the project activities (which are educational aka training projects).
§ 200.456 Participant support costs. Participant support costs as defined in § 200.1<https://www.ecfr.gov/current/title-2/section-200.1> are allowable with the prior approval of the Federal awarding agency.
2 CFR 200.1 "Participant support costs" https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200#p-200.1(Participant%20support%20costs)
Participant support costs means direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects.

This could be budgeted as a Service.  The applicant should have a written agreement with the bus company as a third party vendor.

Hope this helps,

Karen Egan, Associate Director
Grants & Programs/Library Development
Illinois State Library
217-782-7749

Illinois Secretary of State Alexi Giannoulias

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Erica McCormick via lstac
Sent: Thursday, June 15, 2023 11:38 AM
To: Ratliff Warren, Dena (ELC) <dratliffwarren at ky.gov<mailto:dratliffwarren at ky.gov>>; Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: External: Re: [lstac] Allowable Cost Question

NO

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Ratliff Warren, Dena (ELC) via lstac
Sent: Thursday, June 15, 2023 11:31 AM
To: Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: [lstac] Allowable Cost Question

Howdy Brain Trust!

Have a grant applicant that wants the cost of transportation of patrons to programs covered by LSTA funds.  They hire out a private bus company and pay them to transport them to the library for ELL classes.  Is this an allowable cost?

Respectfully,
Dena Ratliff Warren
Kentucky Department for Libraries & Archives
Executive Staff Advisor/Grants Coordinator
300 Coffee Tree Dr.
Frankfort, KY 40601
502-564-6152

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20230620/c88d3244/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.png
Type: image/png
Size: 24533 bytes
Desc: image001.png
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20230620/c88d3244/attachment.png>