Can a percentage of rent be an acceptable programmatic cost?
A. Facility rental costs are normally considered part of the indirect cost base, and are unallowable. If a leased facility is devoted 100% to activities carried out under an EPA Brownfields grant, and charged directly to the Brownfields grant, the costs would not be subject to the statutory administrative cost prohibition. However, such a cost may not be considered reasonable under the applicable OMB Circular and may raise questions during the review process relating to cost effectiveness.
