Brookwood Sago question #2_srm.pdf
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- Attached to
- Brookwood-Sago Mine Safety Grants
- Opportunity number
- FOA-BS-2025-1
About this file
This document is a Questions and Answers (Q&A) document from the U.S. Department of Labor Mine Safety and Health Administration addressing the use of federal grant funds for purchasing existing software licenses. The document provides guidance on five key conditions for using grant funds to acquire software licenses: 1) Necessity and Allocability, requiring the software to be essential for the project and proportionately beneficial, 2) Reasonableness, ensuring the price is market-comparable, 3) Timing of Cost Incurred, mandating that costs must be within the grant period, 4) No Double Billing, preventing duplicate federal funding, and 5) Budget Approval and Compliance, which includes budgeting the costs and considering potential capital asset rules for expensive licenses.
The Q&A specifically responds to a question about purchasing a license for simulation-based and VR-enabled training software that will not be created or owned under the grant. The guidance emphasizes that while such purchases are potentially allowable, they must meet the outlined Uniform Guidance conditions. The document is signed by Shundreka (Shaun) Mims-Randolph, a Supervisory Grants Management Specialist/Grant Officer, and provides clear, structured advice for potential grantees considering software license purchases with federal funds.
Question 2
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Other files
| File | Type | Posted |
|---|---|---|
| Brookwood Sago question 1.pdf | ||
| Brookwood Sago FOA FY2025 Aug 18 2025.pdf |
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Text version
U.S. Department of Labor Mine Safety and Health Administration 200 Constitution Ave. NW, Suite C3522 Washington, DC 20210
We received the following question:
Q: Our proposed project includes a strong emphasis on simulation-based and VR-enabled training. Is a grantee allowed to purchase a license of existing software with Federal funds for the proposed training program? That is, software will not be created or owned under a grant.
A: To use grant funds to purchase or renew existing software licenses, the following conditions generally need to be met under the Uniform Guidance:
1. Necessity & Allocability o The software must be necessary for carrying out the work described in the proposal.
o The cost must be allocable: meaning the grant project must derive benefit from the software, and the cost can be assigned to the grant in a proportionate way.
2. Reasonableness o The price paid must be reasonable (i.e. comparable market-rate, not excessive).
3. Timing of Cost Incurred o The cost must be incurred during the grant period (or during an allowable pre- or post-period if the grant agreement specifies).
o If the license term covers periods outside the grant, only the portion that falls within the grant period is typically allowable.
4. No Double Billing o You can’t use funds to pay for something already paid for with other federal funds for the same purpose / time period.
5. Budget Approval / Compliance o The costs should be budgeted in the proposal.
o If a software license is expensive / capital asset threshold, there may be rules about how to treat or depreciate it.
U.S. Department of Labor Mine Safety and Health Administration 200 Constitution Ave. NW, Suite C3522 Washington, DC 20210
Shundreka (Shaun) Mims-Randolph
Supervisory Grants Management Specialist/Grant Officer
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