11d. Allocating Shared Non-Personnel Costs
The allocation of ‘shared’ direct non-personnel costs can be more complex because specific methods of documentation and allocation are required for each different cost type.
- Non-personnel ‘shared’ direct costs can include the purchase of supplies, food and other materials used or consumed directly by residents. In this case, grantees and sub-recipients would employ standardized procedures for documenting the proportion of each purchase to be associated with appropriate grant sources and program activities, such as purchase order requests or supply requisition forms.
- Other non-personnel ‘shared’ direct costs can include a portion of office space, utilities or transportation costs, for which the costs of rent (or vehicle maintenance) may be prorated according to the percentage of HUD clients served, building square footage used by associated program staff or miles driven.
Examples of Allocating Shared Non-Personnel Costs:
- Agency A utilizes 1,000 square feet of space for its program activities (plus an additional 400 for administration and fundraising) at total monthly cost in rent of $3,500. Within the program space, it operates a Service Coordinator in Multifamily Housing program, as well as several non-HUD programs, all of which are staffed by five full-time workers.
- Each month all staff members complete time sheets that document how they spent their time during that month.
- The portion of total rent and utility costs associated with the 1,000 square feet for program staff – and to be charged to each applicable funding source – is calculated for each funding source and activity. The example above allocates costs for the 5.0 FTE staff as follows:
- First, applying the proportion of ‘program’ to total space (1,000/1,400 sq. ft.)
e.g. 1,000/1,400 = 5/7 of the total cost of $3,500 per month = $2,500. - Then applying the ratio of program-related personnel costs calculated for each of the
2 Service Coordinators, 2 non-HUD case managers, and 1 shared supervisor who spends 20% of her time on Service Coordination-related activities and 80% on non-HUD activities. - This ratio is determined based on the proportion of hours charged by staff to each fund source and activity in the monthly staff time and activity reports, e.g. –
2.2 FTE staff for SC activities = 2.2/5 x $2,500 = $1,100 in SCMF rent cost
2.8 FTE staff for non-HUD activities = 2.8/5 x $2,500 = $1,400 in non-HUD rent
- First, applying the proportion of ‘program’ to total space (1,000/1,400 sq. ft.)
- Agency B utilizes a 9-passenger van to assist clients to get to medical appointments. Only the Section 202 operating contract recognizes this as a reimbursable activity. Thus, for every trip, the van operator keeps track of each client, which program s/he is associated with, and the miles driven on behalf of that client. The amount eligible for HUD reimbursement is determined by calculating the Section 202-eligible portion of total person-miles driven and applying that ratio to the total costs for that trip.
For more information on federal cost allocation principles and practice, please refer to 2 CFR §200.400 (Subpart E–Cost Principles), which can be found on the US Government Publishing Office website.