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Are recipient costs associated with 3D printing of Personal Protective Equipment and Supplies (PPES) for donations allowable?

Not without a regulatory exception. The class exception for donations of equipment and supplies provided by the April 9, 2020, OMB Guidance (PDF) expired on June 16, 2020. Therefore, OGD must provide an exception from 2 CFR 200.443(a) regarding the allowability of the costs of donations and the property disposition regulations at 2 CFR 200.313 and 2 CFR 200.314 on a case by case basis to authorize donations of PPES. 

If the PPES were originally fabricated to protect personnel performing the assistance agreement OGD will consider making the necessary regulatory exceptions if the PPES is no longer needed. Costs for fabricating PPES for the sole purpose of donations to hospitals, medical centers, and other local entities serving the public for COVID-19 response must be eligible under the statutory authority for the assistance agreement. OGD will make statutory authority determinations on a case by case basis. Recipients should follow the procedures described in the answer to the FQ “How should EPA grant recipients request that EPA provide them relief from a requirement due to COVID-19?” to obtain EPA approval for donating 3D printer fabricated PPES to hospitals, medical centers, and other local entities serving the public for the COVID-19 response. OGD may consider whether the recipient has adequately demonstrated that the group or organization that will receive the donation lacks access to the equipment and supplies due to a lack of funding or otherwise when considering regulatory exception requests.

Also, there is no guarantee that EPA will have the resources to provide supplemental funding, so recipients may need to absorb the costs for the donated equipment and supplies with currently approved EPA funds and request an adjustment to their scope of work if their capacity to meet deliverable requirements is impacted.

Return to Frequent Questions about Grants and Coronavirus (COVID-19).