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Brownfields Training, Research &
Technical Assistance Grants and Cooperative Agreements Program - Appendix
A 
| Appendix A. Prohibited Uses of Funds
The following discussion of the administrative cost prohibition is provided to you for illustrative purposes only. If you receive a grant as a result of this competition, your agreement will include a more detailed term and condition specifying requirements for complying with the administrative cost prohibition. The Brownfields law prohibits the use of any "part of a grant or
loan" awarded under Section 104(k) of CERCLA for the payment of:
In implementing the administrative cost prohibition, EPA has made a distinction between prohibited administrative costs and eligible programmatic costs. Administrative CostsProhibited administrative costs are direct costs including those in the form of salaries, benefits, contractual costs, supplies, and data processing charges incurred to comply with most provisions of the "Uniform Administrative Requirements for Grants" contained in 40 CFR Part 30 or 40 CFR Part 31. Direct costs for grant administration are ineligible even if the grantee or sub-grantee is required to carry out the activity under the grant agreement. Ineligible grant administration costs include expenses for:
Prohibited administrative costs are also all indirect costs under OMB Circulars A-21 (Educational Institutions), A-87 (Governments), and A-122 (Non-profit Organizations), and Subpart 31.2 (Commercial Organizations) of the Federal Acquisition Regulation. Indirect costs are not eligible even if your organization has a negotiated indirect cost agreement with a cognizant Federal agency. For governmental recipients, indirect costs include the indirect costs originating in departments of the governmental unit carrying out the assistance agreement and the costs of central governmental services distributed through the central service cost allocation plan. Indirect costs are normally charged to Federal awards by the use of an indirect cost rate. Because of the diverse characteristics and accounting practices of governmental units, the types of costs which may be classified as indirect costs cannot be specified in all situations. However typical examples may include certain State/local-wide central service costs, general administration of the grantee department, accounting and personnel services performed within the grantee department, depreciation or use allowances on buildings and equipment, the costs of operating and maintaining facilities, etc. For non-profit organizations, indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. Typical examples of indirect costs for many non-profit organizations may include depreciation or use allowances on buildings and equipment, the costs of operating and maintaining facilities, and general administrative costs, such as the salaries and expenses of executive officers, personnel administration, and accounting. Programmatic CostsEPA has determined that the administrative cost prohibition does not apply to "programmatic" costs, i.e., direct costs for activities that are integral to achieving the purpose of the assistance agreement, even if the Agency considered the costs to be "administrative" under the prior Brownfields program. In the case of assistance agreements for implementation of Brownfields programs under CERCLA 104(k)(6), programmatic costs would include expenses for providing training, research, and technical assistance. Eligible programmatic costs can include expenses for travel, training, equipment, supplies, reference materials and contractual support if those costs are reasonable and allocable to tasks specified in a recipient's approved scope of work. Direct costs, as defined in the applicable OMB Cost Principle Circular, for the following programmatic activities are not subject to the administrative cost prohibition:
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