Council on Governmental Relations to Office of Federal Financial Management

"200.403(h) - Factors affecting allowability of costs. Publication and printing costs (2 CFR 200.461) and data management and sharing costs (NIH Policy, NOT-OD-21-015) are two examples of allowable costs that may be incurred after project closeout––and as science evolves, the list will grow. For example, the OSTP Public Access Memo requires agencies to establish policies for the sharing of federally funded scientific data and for agencies, in consultation with OMB, to allow researchers to include reasonable associated costs. In order to recognize these costs as allowable and chargeable to federal awards, alternative accounting methodologies are required.

COGR RECOMMENDATION: Define criteria for the class of costs that typically occur after project closeout. When a cost meets the criteria, allow for these costs to be prepaid, charged after the project closeout via a supplement, and/or charged through an allowable, alternative methodology...."