What is the distinction between administrative and eligible program activity costs?  Some activities, such as bookkeeping, often are administrative but also can be directly related to an eligible program activity.

Date Published: July 2011

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Program costs are costs for carrying out and delivering eligible program activities, as identified at 24 C.F.R. § 574.300(b).  These costs include housing assistance activities (i.e., tenant- and project-based rental assistance; operating costs for housing; acquisition, rehabilitation, lease, and repair of facilities; new construction of SROs and community residences only; short-term rent, mortgage and utility assistance; and permanent housing placement activities).  Also included as eligible program activities are supportive services; housing information services; resource identification to establish, develop and coordinate housing assistance resources; and technical assistance (for community residences only).

As defined in 24 C.F.R. § 574.3, administrative costs are 'costs for general management, oversight, coordination, evaluation and reporting on eligible activities.'  The definition further clarifies that administrative costs 'do not include costs directly related to carrying out eligible activities, since those costs are eligible as part of the delivery costs of such activities.'

As one example, the cost of operating a tenant-based rental assistance program (TBRA) includes both the monthly rental assistance payments to landlords for rental units that meet Housing Quality Standards (HQS) and the staff to coordinate and administer those payments.  Thus, a bookkeeper's time for writing rental checks to landlords would be billed under TBRA as an eligible program activity cost, whereas their time spent on payment of general office expenditures would be billed as administrative costs.

Similarly, a supervisor's time may be split between the applicable program activity and administrative costs, depending upon the tasks the supervisor is carrying out.  For example, supervisory participation in case conferences with staff to discuss complex client cases may be an eligible supportive service cost.  However, supervisory activities such as staff meetings and employee evaluations are clearly administrative tasks for managing and providing oversight of the program.  All personnel funded through the HOPWA grant must carefully track their time and record their activity in sufficient detail to document it as an allowable project activity cost or administrative cost.

Tags: HOPWA Program Requirements - Administrative and Planning Costs/Cap