Are there limits on reimbursable expenses under the 2018 NOFA?
Date Published: August 2018
Yes. As a preliminary matter, all costs must be compliant with 2 CFR 200 Subpart E - Cost Principles. There are two categories of reimbursable costs: direct and indirect costs.
Reimbursement for direct costs is governed by Section III(E) of the 2018 NOFA, which indicates that grant funds must be used for delivery of counseling and education services that benefit clients, including the supervision and quality control necessary to provide high quality services. Categories of such eligible costs include the cost of client counseling and education, associated materials, oversight, cost of compliance and quality control, supervision of housing counseling staff, housing counselor training, marketing and outreach initiatives, and costs associated with counselor certification. See 2 CFR 200.413 for a detailed explanation of “Direct costs”.
Individual costs must align with these categories. Examples include but are not limited to: salaries and fringe benefits for counselors (cost of client counseling and education), salaries and fringe benefits for housing counseling program managers (oversight, supervision), travel associated with overseeing a network of affiliates, branches, and sub-grantees (compliance and quality control), tuition for course on loan modification options (housing counselor training), cost of proctored counselor certification exam (counselor certification), etc.
Applicants can seek reimbursement for indirect costs via their negotiated indirect cost rate agreement (if applicable) or by selecting to use the de minimis indirect cost rate (10%). See 2 CFR 200.414 for a detailed explanation of “Indirect costs”.
If you are unsure whether an activity is reimbursable under the 2018 NOFA, contact your HUD POC for guidance.