Promotional Items Prior Approval Process Questions and Answers (Q&As)

Transcription

1 Promotional Items Prior Approval Process Questions and Answers (Q&As) Q 1: What is the proviso language included in the General Appropriations Act (GAA)? A: The following language was included in the GAA for the state budgetary year ending June 30, 2012: From the funds provided in Specific Appropriation 2006, any expenditures by regional workforce boards for "outreach," "advertising," or "public relations" must have a direct program benefit and shall be spent in strict accordance with all applicable federal regulations and guidance. Costs of promotional items, including but not limited to capes, blankets, clothing, and memorabilia, including models, gifts, and souvenirs, which exceed $5,000 for outreach purposes must be approved prior to purchase by the Agency for Workforce Innovation. Q 2: What is a promotional item? A: Promotional items may include generic pens, mouse pads, cups, tumblers, flash drives, tote bags, umbrellas, t shirts, and other similar items purchased for distribution to the general public. Q 3: What is NOT considered a promotional item? A: Examples of items that are not 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 items are purchased to be given to the public, as described in Q2 above. For example, imprinted notepads for internal use are considered supplies, while the same item purchased for distribution to potential participants/employers would be considered a promotional item. Items purchased to provide incentives for recognition and achievement to eligible youth are not considered promotional items. Q 4: Can I purchase promotional items (including but not limited to capes, blankets, clothing, and memorabilia, including models, gifts, and souvenirs) using grant funds? A: Generally no. OMB Circular A 122 (1) (f) (3) and OMB Circular A 87 (1) (f) (3) (highlighted copies provided at the end of these Q&A s) generally prohibits the use of federal grant funds for promotional items and memorabilia, including models, gifts, and souvenirs. Q 5: What if the promotional item is not generic and is used as an informational item for grant outreach purposes? A: With certain grant funds (see Table 1) and with certain caveats, a promotional item may be considered an allowable informational item for outreach purposes by including a message on the item that directly communicates the availability and/or benefit of grant program services to intended recipients of the grant services (e.g. unemployed and employers) or to the general public. Q 6: What is outreach? A: Outreach is an activity designed to inform and educate the general public about the availability of program services and is used to recruit targeted individuals and other customer groups such as employers who may benefit from the program. Q 7: Which funding sources allow certain promotional items to be considered allowable informational items for outreach purposes?

2 A: Generally, USDOL ETA programs like the Workforce Investment Act and Wagner Peyser Act Programs allow this treatment. Other programs depend on grantor preference on the issue or the nature of the services provided. A matrix of the workforce funding sources and whether the grant allows the purchase of an informational item are listed at the end of these Q&As. See Table 1. Q 8: What message must be included on a promotional item for it to qualify as an allowable informational item? A: The minimum information is a tag line that specifically ties the item to the benefitting funding program(s) and which provides information on how to access grant funded services. For example, Need help finding a job? We are your job connection service for this area along with the website, phone number, and/or other information that would direct the user to you for the benefitting services. Q 9: Can a promotional item that only includes the region s name and logo be purchased? A:. OMB Circular A 122 (1) (f) (4) and OMB Circular A 87 (1) (f) (4) prohibit the purchase of items that only promote the organization. Q 10: When and how must I get prior approval for purchases of promotional items that qualify as information items? A: The Proviso Language shown in Q1 requires prior approval for any purchase (in total) of promotional items that qualify as informational items that exceeds $5,000. The specific purchase, exact message to be included on the items, the intended recipients of the items, and specific funding sources with supporting justification, must be sent to the Department of Economic Opportunity at priorapprovalrequest@deo.myflorida.com using the individual prior approval form. Be sure to note the anticipated volume of items that you expect to need per time 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? A:. The total purchase exceeds $5,000, therefore prior approval is required. The limit is on the aggregate purchase, not the unit cost. Q 12: I ordered $3,000 of informational items last week and realized I need to purchase $3,000 of additional items this week. Do I need prior approval? A:, in this circumstance, it is clear that the final intent or need was to purchase $6,000 of information items. 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? A: Most cost pools used by Regional Workforce Boards and One Stop Career Centers include virtually all funding sources and would therefore not be allowable. Cost pools can only 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 matrix of grants and the allowability of promotional items, which is included in table 1 at the end of the Q&As. Q 14: Do I need prior approval for the purchase of business cards?

3 A:. Business cards are considered supplies, as described in Q3 above. Q 15: Can I place an ad in a magazine without requesting prior approval? A:. As long as the ad is necessary and reasonable for the grant sources charged, and meets the purposes specified in OMB Circular A 87 or A 122, Attachment B, Selected Items of Cost, Item 1 that defines allowable advertising and public relations costs. The proviso language only requires prior approval for promotional/information items, not all outreach purchases. Q 16: Can I purchase a table cloth with a logo on it for a display at an event? A: A table cloth purchased for the purpose of promoting the organization at Agency sponsored events such as job fairs, etc. would be allowable as an office supply without prior approval. A table cloth purchased for the purpose of promoting the organization at non Agency sponsored events would be considered unallowable if it only contained the organization s logo and did not also include an outreach message. If the item included the tag line requirements then it could be allowable using a permissible funding source as an informational item but would require prior approval if the purchase met the threshold requirements of the prior approval policy. Table 1 Grant Allowability for Purchases of Informational Items if Prior Approval is Granted Program Title Food Stamp, Employment and Training Allowable to Purchase Informational Items? Wagner Peyser Employment Services Unemployment Insurance (UI) Reemployment and Eligibility Assessments Trade Adjustment Assistance WIA Formula awards (Adult, Dislocated Worker and Youth) WIA State Level, te 1 Disabled Veterans Outreach Program (DVOP) Local Veterans Employment Representative Program (LVER) Veteran's Incentive Awards Welfare Transition Other grant awards te 2 tes: (1) Allowable, unless restricted due to special terms in the NFA. (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. a. The term advertising costs means the costs of advertising media and corollary administrative costs. 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 costs are those which are solely for: (1) The recruitment of personnel required for the performance by the non-profit organization of obligations arising under a Federal award (See also Attachment B, paragraph 41, Recruiting costs, and paragraph 42, Relocation costs); (2) The procurement of goods and services for the performance of a Federal award; (3) The disposal of scrap or surplus materials acquired 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 meet 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 (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 the extent that such activities are limited to communication and liaison necessary keep the public informed on matters of public concern, such as notices of Federal 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 sponsored work and other work of the non-profit organization, are allowable to the extent that the principles in Attachment A, paragraphs B. ("Direct Costs") 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, convocations, or other events related to other activities of the non-profit organization, 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 designed solely to promote the non-profit organization.

5 OMB A-87, Attachment B 1. Advertising and public relations costs. a. The term advertising costs means the costs of advertising media and corollary administrative costs. 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 governmental unit 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 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; (3) The disposal of scrap or surplus materials acquired in the performance of a Federal award except when institutions are reimbursed for disposal costs at a predetermined amount; or (4) Other specific purposes necessary to meet 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 (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 the extent that such activities are limited to communication and liaison necessary keep the public informed on matters of public concern, such as notices of Federal contract/grant awards, financial 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 Costs") 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 designed solely to promote the governmental unit.