TLDR
Subpart E's 'reasonable' test is subjective in theory and brutal in audit practice. A cost that appears reasonable to a program director will be questioned if comparable market prices weren't checked and documented at the time of purchase.
2 CFR 200 Subpart E: Cost Principles for Federal Awards
The Uniform Guidance’s cost principles — codified in 2 CFR 200 Subpart E — determine which of your expenditures the federal government will reimburse. Understanding them is not optional for nonprofits receiving federal awards.
Subpart E operates on four general tests (necessary and reasonable, conforms to limitations, consistently applied, adequately documented), supplemented by 56 sections of specific rules for individual cost types. Most organizations know the four general tests. Most organizations miss the specific rules.
The Four Allowability Tests
Every cost charged to a federal award must satisfy all four criteria simultaneously.
Test 1: Necessary and reasonable A cost is necessary if it is required for the proper and efficient performance of the award. A cost is reasonable if a prudent person would incur it under the same circumstances. These are separate analyses: a cost can be necessary but unreasonable in amount (a necessary consultant engaged at twice the market rate) or reasonable in amount but unnecessary to the award.
Test 2: Conforms to limitations Costs must comply with any limitations established in the federal award’s terms and conditions, applicable federal statutes, and Subpart E itself. Even a cost that passes the reasonableness test fails if the award terms prohibit it.
Test 3: Consistently applied The treatment of a cost must be consistent across the organization’s activities. A cost type treated as indirect for non-federal work cannot be claimed as direct on a federal award. An organization cannot selectively apply cost accounting methods to maximize federal reimbursement. Inconsistency is both a compliance violation and an audit trigger.
Test 4: Adequately documented No documentation, no deduction. Documentation requirements vary by cost type but typically include purchase records, receipts, time records for labor, and approval documentation for significant purchases.
Selected Items of Cost: Key Categories
The selected items provisions (200.420–200.476) establish specific rules for particular expense types:
| Cost type | Section | Key rule |
|---|---|---|
| Advertising | 200.421 | Allowable only for specific recruitment or program requirements |
| Alcoholic beverages | 200.423 | Never allowable |
| Bad debts | 200.426 | Never allowable |
| Compensation | 200.431 | Must match organizational pay scales and market rates |
| Entertainment | 200.438 | Never allowable without specific award authorization |
| Equipment | 200.439 | Capitalize at $10,000 (or organizational threshold if lower) |
| Fines and penalties | 200.441 | Never allowable |
| Lobbying | 200.450 | Never allowable except narrow exceptions |
| Meetings and conferences | 200.432 | Allowable when necessary; program, not recreation |
| Professional services | 200.459 | Allowable; must be reasonable; foreign entity restrictions apply |
| Rent | 200.465 | Allowable; arm’s-length and cannot exceed fair market value |
| Salaries/wages | 200.430 | Allowable; must be supported by time records |
| Travel | 200.475 | Allowable; must follow written travel policy; mileage at IRS rate or actual cost |
Labor Costs and Effort Reporting
Personnel costs represent the largest single category of federal expenditures for most nonprofits. Subpart E’s requirements for labor cost documentation are specific:
Under 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must: be supported by a system of internal controls; reasonably reflect the total activity for which the employee is compensated; encompass both federally-assisted and all other activities; and be kept in a manner consistent with the nonprofit’s established accounting practices.
“Time records” under Subpart E do not have to be daily timesheets. They can be semi-annual certifications, monthly effort reports, or other documentation that the organization and its auditors agree accurately represents effort allocation. But they must exist. The absence of any effort documentation is among the most common single-audit findings.
How GrantPipe Helps
GrantPipe’s grant management module allocates costs to awards as they are posted, with the cost-type classification built into the transaction entry. When a purchase is recorded, the grant manager selects the cost objective and the system validates the charge against the award budget. The audit trail captures every allocation decision, including who approved it and when — the documentation that Subpart E requires for adequate cost documentation. Pre-drawdown reports flag unallocated costs and costs approaching budget caps, giving finance teams the opportunity to remove unallowable items before they reach the federal payment system.
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Source: 2 CFR Part 200, Section 200.346
- Cost objective
- A program, function, activity, award, organizational subdivision, contract, or work unit for which cost data are desired and for which provision is made to accumulate and measure the cost of processes, products, jobs, and capitals or other cost objectives.
DEFINITION
- Final cost objective
- A cost objective that has allocated to it both direct and indirect costs, and is one of the final accumulation points for federal costing purposes. A federal award is a final cost objective.
DEFINITION
- Intermediate cost objective
- A cost objective that is used to accumulate indirect costs or service costs, which are subsequently allocated to one or more indirect cost pools or final cost objectives.
DEFINITION
- Effort reporting
- The system of documentation that supports the allocation of labor costs to federal awards. Under Subpart E, personnel engaged in multiple activities or cost objectives must maintain records reflecting the proportion of time spent on each.
DEFINITION
- Selected items of cost
- Specific cost categories addressed in 2 CFR 200.420–200.476, which establish rules for particular expense types including compensation, travel, equipment, entertainment, and others. The selected items of cost sections supplement the general allowability tests.
DEFINITION
Q&A
How does the 'reasonable' test apply in practice?
A cost is reasonable if, in its nature and amount, it does not exceed what a prudent person would incur under the circumstances prevailing at the time the decision to incur the cost was made. The IRS-style 'prudent person' standard means auditors evaluate the cost as of the time it was incurred — not with hindsight. Documentation of market-rate comparisons at the time of purchase is the primary defense against a reasonableness challenge.
Q&A
What is the consistently applied requirement?
Costs must be charged to the federal award in a consistent manner — the same way they are charged to other programs and activities. If an organization treats a cost as indirect for non-federal work but tries to charge it as direct to a federal award, that inconsistency violates the consistently applied standard. Documenting cost allocation methods in writing and applying them uniformly is the safeguard.
Q&A
What selected items of cost are most relevant to nonprofits?
The most frequently encountered selected items: compensation (200.431), fringe benefits (200.431), travel (200.475), meetings and conferences (200.432), professional services (200.459), materials and supplies (200.453), equipment (200.439), depreciation (200.436), rent (200.465), and advertising (200.421). Each section specifies when and how the cost is allowable.
Frequently asked