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  • Clarifies that non-Federal entities may charge the Federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the Federal award. 
  • Publication costs for electronic and print media, including distribution, promotion, and general handling are allowable. 
  • If these costs are not identifiable with a particular cost objective, they should be allocated as indirect costs to all benefiting activities of the non-Federal entity. 

Action Plan

  • In developing your proposal, make sure that the costs for publication and printing are specified in the budget. The budget justification should include an explanation of why the costs will be incurred post-award.
  • Review internal processes and identify impact on subrecipients and determine how many days (e.g. 60 days) they have for these type of costs (and these costs must be included in final invoice) and update Division of Research reference materials and internal work instructions. (Anthony Adamczyk





  • Reviewing internal processes, updating reference material and subrecipient documents.
  • PI quick guide to be completed.