1 Promotional Prior Approval Process Items Answers (Q&As) and Questions What is the proviso language included in the General Appropriations Act (GAA)? 1: Q 2012: language was included in the GAA for The the state budgetary year ending June 30, following A: the funds provided in Specific Appropriation 2006, any expenditures by regional workforce From for "outreach," "advertising," or boards relations" must have a direct program benefit and "public spent in strict accordance with all applicable federal regulations and guidance. Costs of shall be items, including but not limited to capes, blankets, clothing, and memorabilia, promotional models, gifts, and souvenirs, which exceed $5,000 for outreach purposes must be including prior to purchase by the Agency for Workforce Innovation. approved Q 2: What is a promotional item? Promotional items may include generic pens, mouse pads, cups, tumblers, flash drives, tote bags, umbrellas, t ‐ A: and other similar items purchased for distribution to the general public. shirts, What Q is NOT considered a promotional item? 3: of items Examples are not A: that considered promotional in nature are office stationery, building signs, employee shirts and caps purchased to help identify program staff to the public, and office supplies, unless the notepads purchased to be given to the items public, as described in Q2 above. For example, imprinted are for internal use are considered supplies, while the item purchased for distribution to potential same participants/employers would be considered a promotional item. Items purchased to provide incentives for recognition achievement to eligible youth are not and considered items. promotional blankets, Can I purchase promotional items (including but not limited Q capes, 4: clothing, and memorabilia, to gifts, and souvenirs) models, using grant funds? including Generally no. OMB Circular A ‐ 122 (1) (f) (3) and OMB Circular A ‐ 87 (1) (f) (3) (highlighted A: provided at copies the end of these Q&A’s) generally prohibits the use of federal grant funds for promotional items and memorabilia, gifts, and souvenirs. including models, 5: What if the promotional item is Q generic and is used as an “informational item” for grant outreach not purposes? A: With certain grant funds (see Table 1) and with certain caveats, a promotional item may be considered an allowable item” for outreach purposes by including a message on the item that directly “informational services availability and/or benefit of grant program communicates to intended recipients of the grant the general services unemployed and employers) or to the (e.g. public. 6: What Q is outreach? A: Outreach is an activity designed to inform and educate the general public about the availability of program services is used to recruit targeted individuals and other and customer groups such as employers who may benefit from the program. 7: Which funding sources allow certain promotional items Q to be considered allowable informational items for outreach purposes?
2 A: USDOL ETA programs like the Workforce Investment Act and Wagner Peyser Act Programs allow this Generally, Other programs depend on grantor preference on the issue or the nature of the services provided. A treatment. of matrix workforce funding sources and whether the grant allows the purchase of an informational item are the end of these Q&As. See at Table 1. listed the for What message must be on a promotional item it to qualify as an allowable informational 8: Q included item? The minimum information is a “tag line” that specifically A: ties the item to the benefitting funding program(s) provides information on how to access grant funded services. For example, “Need help finding a job? and which are your job connection service for this area” along with the website, phone number, and/or other We would direct the user to that for the benefitting services. information you 9: Can a promotional item that only includes the region’s name and logo be purchased? Q No. OMB Circular A ‐ 122 (1) (f) (4) and OMB Circular A ‐ 87 (1) (f) (4) prohibit the purchase of items that only A: promote organization. the When and how must I get prior approval for purchases of promotional items that qualify as Q information 10: items? The Proviso Language shown in Q1 requires prior approval for any purchase (in total) of promotional items A: qualify as informational items that exceeds $5,000. The specific purchase, exact message to be included on that recipients the intended the of the items, and specific funding sources with supporting justification, must be items, the Department of Economic Opportunity at [email protected] sent to using the prior approval form. Be sure to note the anticipated volume of items that individual expect to need per time you period. For example, “we plan to purchase 1,200 imprinted cups that we expect to use within six months”. Q 11: I am purchasing 2,000 outreach informational items at $5/each. Since one item is only $5, do I need prior approval? Yes. The total purchase exceeds $5,000, therefore prior approval is required. The limit is on the aggregate A: cost. not unit the purchase, 12: I ordered $3,000 of informational items last week and realized Q I need to purchase $3,000 of additional week. Do I this need prior approval? items Yes, in this circumstance, it A: clear that the final intent or need was to purchase $6,000 of information items. is However, if the second purchase was made later in the year, it might not be viewed as a split purchase and would not require prior approval. Common sense is necessary in all cases, but you should follow the intent of the requirement if you have any doubt. It is better to request the approval if you are uncertain. Q 13: Can I charge informational items costs to the Board’s cost pool? cost pools used by Regional Workforce Boards and One ‐ Stop Career A: Centers include virtually all funding Most sources would therefore not be allowable. Cost pools can only and include items that are allowable for all of the funding sources that make up that cost pool and are to be charged their allocable share of the pool. See the end matrix of grants and the allowability of promotional items, which is included in table 1 at the of the Q&As. 14: Do I need prior Q for the purchase of business cards? approval
3 A: Business cards are considered supplies, as described in Q3 above. No. Q Can I place an ad in a magazine without 15: approval? prior requesting long as the ad is necessary and Yes. reasonable for As the grant sources charged, and meets the purposes A: in OMB Circular A ‐ 87 specified or A ‐ 122, Attachment B, Selected Items of Cost, Item 1 that defines allowable public relations costs. The proviso and only requires prior approval for advertising language items, not all outreach purchases. promotional/information Q 16: Can I purchase a table cloth with a logo on it for a display at an event? table cloth purchased for the purpose of promoting the organization at Agency sponsored events such as A: job A purpose would be allowable as an office supply fairs, without prior approval. A table cloth purchased for the etc. of promoting the organization at non ‐ Agency sponsored would be considered unallowable if it only events contained the organization’s logo and did not also include an outreach message. If the item included the “tag line” then it could be allowable using a permissible funding source as an informational item but requirements prior approval if the purchase met the threshold requirements of the prior approval policy. would require 1 Table for Purchases of Grant Allowability Items if Prior Approval is Granted Informational Allowable to Purchase Informational Program Items? Title Employment and Training Food No Stamp, Employment Wagner Services Yes Peyser Insurance (UI) No Unemployment Reemployment and Eligibility Assessments No Trade Assistance No Adjustment awards (Adult, Dislocated Worker and Youth) Yes WIA Formula State Level Yes, Note 1 WIA Disabled Outreach Program (DVOP) No Veterans’ No Employment Local Program (LVER) Veterans’ Representative Veteran's Incentive Awards Yes Welfare Transition No Other awards Note 2 grant Notes: Allowable, unless restricted due (1) special terms in the NFA. to (2) Depends on the specific grant requirements. Contact the Grant Manager listed on the NFA with any questions.
4 OMB A-122 Attachment B 1. Advertising and public relations costs. corollary administrative costs. a. The term advertising costs mean s the costs of advertising media and Advertising media include magazines, newspapers, radio and television, direct mail, exhibits, electronic or computer transmittals, and the like. b. The term public relations includes community relations and means those activities dedicated to maintaining the image of the non-profit organization or maintaining or promoting understanding and favorable relations with the community or public at large or any segment of the public. c. The only allowable advertising cost s are those which are solely for: (1) The recruitment of personnel required for the perform ance by the non-profit organization of obligations B, paragraph 41, Recruiting costs, and paragraph 42, arising under a Federal award (See also Attachment Relocation costs); for the performance of a Federal award; (2) The procurement of goods and services (3) The disposal of scrap or surplus materials acquire d in the performance of a Federal award except when non-profit organizations are reimbursed for disposal costs at a predetermined amount; or (4) Other specific purposes necessary to m eet the requirements of the Federal award. d. The only allowable public relations costs are: (1) Costs specifically required by the Federal award; (2) Costs of communicating with the public and press pertaining to specific activities or accomplishments which result from performance of Federal awards (t hese costs are considered necessary as part of the outreach effort for the Federal award); or dia and government public relations officers, to the (3) Costs of conducting general liaison with news me cation and liaison necessary keep the public informed on extent that such activities are limited to communi matters of public concern, such as notices of Fe deral contract/grant awards , financial matters, etc. e. Costs identified in subparagraphs c and d if incurred for more than one Federal award or for both tion, are allowable to the extent that the principles sponsored work and other work of the non-profit organiza in Attachment A, paragraphs B. ("Direct Cost s") and C. ("Indirect Costs") are observed. f. Unallowable advertising and public relations costs include the following: (1) All advertising and public relations costs other than as specified in subparagraphs c, d, and e; (2) Costs of meetings, conventions, conv other activities of the non-profit ocations, or other events related to organization, including: (a) Costs of displays, demonstrations, and exhibits; (b) Costs of meeting rooms, hospi tality suites, and other special facilities used in conjunction with shows and other special events; and (c) Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, and providing briefings; (3) Costs of promotional items and memorabilia, including models, gifts, and souvenirs; (4) Costs of advertising and public relations desi gned solely to promote the non-profit organization.
5 OMB A-87, Attachment B . 1. Advertising and public relations costs advertising media and corollary administrative costs. a. The term advertising costs means the costs of Advertising media include magazines, newspapers, radio an d television, direct mail, exhibits, electronic or computer transmittals, and the like. relations and means those activities dedicated to b. The term public relations includes community maintaining the image of the governmental unit or ma intaining or promoting understanding and favorable relations with the community or public at large or any segment of the public. c. The only allowable advertising costs are those which are solely for: (1) The recruitment of personnel required for the performance by the governmental unit of obligations arising under a Federal award; (2) The procurement of goods and services for the performance of a Federal award; acquired in the performance of a Federal award (3) The disposal of scrap or surplus materials except when institutions are reimbursed for di sposal costs at a predetermined amount; or eet the requirements of the Federal award. (4) Other specific purposes necessary to m d. The only allowable public relations costs are: (1) Costs specifically required by the Federal award; (2) Costs of communicating with the public and press pertaining to specific activities or accomplishments which result from performance of Federal awards (these costs are considered necessary as part of the outreach effort for the Federal award); or (3) Costs of conducting general liaison with news media and government public relations officers, to communication and liaison necessary keep the public to the extent that such activities are limited t/grant awards, financial informed on matters of public concern, such as notices of Federal contrac matters, etc. e. Costs identified in sections 1.c and 1.d, if incurred for more than one Federal award or for both sponsored work and other work of the governmental unit, are allowable to the extent that the principles in Attachment A, sections E. ("Direct Cost s") and F. ("Indirect Costs") are observed. f. Unallowable advertising and public relations costs include the following: (1) All advertising and public relations costs other than as specified in subsections c, d, and e; (2) Costs of meetings, conventions, convocations, or other events related to other activities of the governmental unit, including: (a) Costs of displays, demonstrations, and exhibits; (b) Costs of meeting rooms, hospitality suites, and other special facilities used in conjunction with shows and other special events; and (c) Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, and providing briefings; (3) Costs of promotional items and memorabilia, including models, gifts, and souvenirs; (4) Costs of advertising and public relations de signed solely to promote the governmental unit.