520.002 Staff Education, Association Memberships, Training Fees and Insurance Payments Using Contract Funds

Policy Number 520.002
Effective Date August 9, 1999
Revision Date May 25, 2000
Approval Authority TB/HIV/STD Section Director

1.0 Purpose

This policy will describe what fees, licensure, memberships, training and educational costs a contractor of the Texas Department of State Health Services (DSHS), TB/HIV/STD Section (Section) may pay for using federal or state services and prevention contract funds.

2.0 Background

Contractors who receive funds from the Section may occasionally question whether certain costs may be paid using federal and/or state contract funds. These costs include training to enhance the skills of volunteers and employees, payment for certain licenses and memberships or payments for actual educational expenses.

3.0 Authority

1 TAC, §§ 5.141-5.167; Texas Uniform Grants Management Standards (UGMS) Attachment A; Office of Management and Budget (OMB) Circular A-87, A-122, or A-133.

4.0 Definitions Applied to Section Policy

Advertising - announcements, solicitations and notices placed through media.

Media - magazines, newspapers, radio, television, direct mail, exhibits, the Internet and other mediums which charge for providing advertising services.

5.0 Prior Approval

Contractors with questions about whether a cost is allowed should refer to the Texas UGMS and the OMB circular and attachment cited in the authority section of this policy. When reading the circular, contractors will note that some items indicate that prior approval must be obtained before spending contract funds for a particular expense. Prior approval means that the contractor must call or write the appropriate Section staff to receive written approval to spend any funds for a particular purpose. This requirement applies to federal and state funds.

When funds are spent in an area in which prior approval was required, and such approval was not given, the state will not reimburse the contractor for those funds and the contractor may be sanctioned for spending the funds inappropriately (See Section Policy No. 540.001).

The specific costs included in a grant application are considered to have met the prior approval requirement once the grant’s budget has been successfully negotiated. The requirement for receiving approval prior to expending project funds does not pertain to costs contained in a negotiated contract if documented.

The requirement to receive prior approval also applies to grant subrecipients.

6.0 Use of Funds

Unless otherwise specified, the provisions found in this policy apply to all funds allocated through the Bureau.

7.0 Allowable Costs

The following costs are allowable. However, the amount of funds allocated for expenditure is negotiable when specifically identified in a grant application budget. Costs included in grant applications must be reasonable and prudent and, may be considered as direct and indirect costs of doing business. Costs which require an institutional prior approval (IPA) are identified with a “Yes” in the IPA column.

The contractor should carefully evaluate the requested training to determine its pertinence to the overall operation and administration of funds according to the basic considerations outlined in UGMS Attachment A and applicable OMB Circulars.

7.1 Staff and boards of directors

# IPA Type of Cost
1. No Bonding of employees or officials
2. No Medical or dental insurance for employees
3. No Director and Officer (D&O) indemnification insurance
4. Yes Consultant services authorized in HIV/STD Policy No. 520.001, “Consultant Services and Consulting Fees Paid by a Contractor Through Direct Costs”
5. No Registration and associated costs to attend the Texas HIV/STD Conference sponsored by the DSHS
6. Yes Membership in civic, business, technical and professional organizations when membership in such an organization is essential to the performance of a federal or state program
7. Yes Subscriptions to civic, business, professional, and technical periodicals
8. Yes Part-time education, at an undergraduate or post-graduate college level, when the course or degree pursued is relative to the field in which the employee is now working or may reasonably be expected to work. Costs are limited to training materials, textbooks and fees charged by the educational institution
9. Yes Tuition, fees, training materials, and textbooks in connection with full-time education at a post-graduate (not undergraduate) college level related to the field in which the employee is now working or may reasonably be expected to work. Subsistence, salary, or any other side benefits are not covered. Costs are limited to those spent during a period not to exceed one school year per trained employee. In unusual cases the period may be extended.
10. Yes Attendance for up to 16 weeks per employee per year at specialized programs designed to enhance the effectiveness of executives or managers, or to prepare employees for such positions. Such costs include enrollment fees, training materials, textbooks and related charges, employees' salaries, subsistence, and travel. Costs allowable under this paragraph do not include those for courses that are part of a degree-oriented curriculum discussed above.
11. Yes Training and education costs, including those for continuing education credits, in excess of those otherwise stated above may be allowed with Bureau approval. To be considered for approval, the organization must demonstrate that such costs are consistently incurred in carrying out an established training and education program. The course or degree pursued must be relative to the field in which the employee is now working or may reasonably be expected to work.


7.2 Additional requirements for IPA items 8, 9, 10 and 11

  • Education and/or training must be directly related to the job duties of the individual who will attend such education and/or training
  • The contractor must establish a maximum dollar amount to be spent on education and/or training per individual
  • The contractor must require the individual receiving education and/or training to sign a reciprocal agreement obligating the individual to a specified length of service for each semester paid for by the contractor

These requirements are subject to monitoring by the Bureau during routine site visits.

7.3 Consortia, community planning groups, and other advisory groups

Only training costs related to consortia, community planning groups and, other such advisory groups (when the formation of such a group is required by related federal or state programs) are allowable.

Funds may not be used to insure or bond any member of an advisory group.

8.0 Unallowable Costs

The following costs are not allowed:

  1. entertainment unless such costs are directly related to the program’s scope of work and approved by the Bureau;
  2. funds awarded may not be used to pay for professional licensure or to meet program licensure requirements;
  3. any funds associated with an organization’s lobbying activity (including salaries, expenses, travel, per diem, contracts for a professional lobbyist, or membership in any organization whose mission includes lobbying), and
  4. malpractice insurance.

9.0 Revision History

Date Action Section
9/1/2017 Changed "TB/HIV/STD Unit" to "TB/HIV/STD Section" to reflect new program designation -
9/11/2014 Converted format (Word to HTML) -
11/13/2002 Converted format (WordPerfect to Word) -
5/25/2000 Numerous changes All