In response to questions from numerous members, NAVREF has developed a sample policy on NPC payment for subscriptions and memberships. This policy reflects VHA Handbook 1200.17 provision 13.d.(1) which specifies “NPC funds may be used to pay for publications and scientific journals that facilitate VA's research and education missions.”  The dilemma for NPCs is that often it is necessary or cost-effective to purchase a membership in a scientific society in order to subscribe to scientific journals.  Individual memberships are usually significantly less costly than corporate memberships.  A reduced conference registration fee often is an added benefit of paying for an individual membership in a professional society.

• Brief Summaries of Other Guidance on Payments for Memberships
• Sample Subscriptions and Dues Policy
• Sample NPC SOP for Evaluating Subscriptions and Dues

A Compilation of Positions on Payment/Reimbursement for Subscriptions and Dues
November 2004

Federal Ethics Standards prohibit acceptance of “gifts” (anything of monetary value) unless they cost less than $20 or fall under one of the other exceptions in 5 USC  2635.204. Therefore, acceptance by VA employees of a “gift” of a membership is likely to be prohibited under the ethics regulations. However, in a 1996 opinion, VA OGC concluded that “the rules pertaining to gifts from ‘prohibited sources’ and gifts solicited or accepted because of an employee's official position are not applicable to gifts from research corporations.”

Handbook 1200.17. 13.d.(1) Publications. NPC funds may be used to pay for publications and scientific journals that facilitate VA's research and education missions.

Handbook 1200.17. 13.d.(2) Professional Memberships. NPC funds may be used to pay for corporate memberships in professional organizations that facilitate VA's research and education missions.

Internal Revenue Service. The IRS allows a personal or business tax deduction for work related memberships in professional organizations (IRS Publications 529 and 15-B). Professional memberships may be provided as fringe benefits to employees and non-employees. Generally, the value of fringe benefits is not taxable income.

5 USC 5946 prohibits the use of appropriated funds to pay a federal employee’s membership fees in any organization unless the payment is authorized by a specific appropriation or express terms in a general appropriation, or the membership is part of an employee training program authorized by 5 USC 4109 and 4110.

Various OGC and GAO legal opinions hold that appropriated funds may be used to pay for an agency’s membership in a private organization so long as the primary benefit of the membership accrues to the agency rather than its employees, and the agency determines that its membership in a particular organization is necessary to carry out its statutory functions.

OMB Circular A-122 Cost Principles for Nonprofit Organizations. Selected items of cost: #30. Memberships, subscriptions, and professional activity costs.

a. Costs of the organization’s membership in business, technical, and professional organizations are allowable.

b. Costs of the organization’s subscriptions to business, professional and technical periodicals are allowable.

c. Costs of meetings and conferences, when the primary purpose is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, and other items incidental to such meetings or conferences.

d. Costs of membership in any civic or community organization are allowable with prior approval by federal cognizant agency.

e. Costs of membership in any country club or social or dining club or organization are unallowable.

NIH Grants Policy Statement (2003) section on selected items of cost (page 91): Dues or Membership Fee - Allowable as an F&A cost for organizational membership in business, professional or technical organizations or societies.

NPC is committed to fostering access to scientific information that allows VA and NPC personnel to remain current in their fields and apprised of cutting edge developments for the benefit of VA research and education. This involves subscribing to journals as well as facilitating VA investigators’ full participation in scientific and educational organizations and conferences.

Personnel may request payment or reimbursement for the cost of subscriptions for research related publications and approved educational materials that provide a clear benefit for VA research or education. Subscription requests must indicate a VAMC business - not residential - address for delivery. 

If a membership is necessary to obtain the publication, or if it is cost-effective to pay for a membership in order to obtain the publication and/or to attend meetings at a significantly reduced rate, NPC may pay the dues. However, the organization must have a research orientation as demonstrated by publication of research journal(s) and/or must hold scientific meetings of benefit to VA research. Prior approval of the Education Committee is required for educational subscriptions and/or memberships that have no research relevance.

Add to travel or conference registration policy or as a note to the subscription or membership policies: If an organization offers no justifiable publications, but holds a meeting that has research relevance or educational value, and the cost of dues is justified by a reduction in the meeting registration fee, when practical, membership dues will be paid at the same time as the registration fee. (Purpose is to avoid paying for a membership justified by access to a lower registration fee, but subsequently the individual is unable to attend the meeting.)

Purpose: To assess whether NPC will pay for a membership as opposed to a non-member subscription fee.

NPC staff evaluates each subscription request and decides whether to pay for a subscription or dues on the basis of research relevance or in the case of educational subscriptions, whether there is a benefit to VA or NPC employees, or to VA patients, and business prudence. For example (see table below):

Alternative if an NPC wants the PI to contact the organization rather than NPC staff - may be advisable for a very large NPC: Requestor must provide NPC with an analysis of each subscription/membership request. See table that follows. NPC staff decides whether to pay for a subscription or dues on the basis of research relevance or in the case of educational subscriptions, whether there is a benefit to VA or NPC employees, or to VA patients, and business prudence. Examples for illustration purposes only:

Member-
ship
Dues