When Are Communications Costs Chargeable to School Construction Bond Funds?
When Are Communications Costs Chargeable to
School Construction Bond Funds?
The short answer is that communications costs directly supporting school construction bond (SCB) activities are allowable. Examples of allowable expenses include the costs of doing a public hearing as part of an Environmental Impact Report (EIR) for a new school as required by the California Environmental Quality Act (CEQA), press releases for the opening of a new school, or the costs of a public information office that does SCB work. The costs of hiring external professionals, such as public relations or community communications firms, may also be allowable, depending upon the work performed.
As always, with charges to Prop. 39 SCB funds, it is best to have cost charging and cost allocation plans established in advance, including an agreement with agency fiscal and legal offices and bond counsel as appropriate.
Non-allowable communication costs include support of general school administration activities, such as a press release announcing the hiring a new school superintendent, public information on registering students for pre-kindergarten, or announcing a public hearing on the entity’s annual budget.
It is common for some offices in a district to split their work and time between SCB and general activities; in such cases, it is possible to separate the costs between SCB funds and non-SCB funds if proper records are kept. The best practice is for the employees in such offices to do daily time sheets, allocating their work between bond-funded and other activities by an approved cost allocation plan.