For a single Award, where the controlled substance(s) are required to achieve the objectives of the Award, charging the annual license fee to the Award as a direct cost would be allowable. If the controlled substance(s) are required to achieve the objectives for multiple Awards or other activities, allocating the annual fee to each of the Awards or other activities on some reasonable basis as a direct cost would be allowable. In cases where it is not possible to determine proportional benefits, the annual license fee should be treated as an F&A cost.
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