My company supports multiple government agencies at multiple installations of multiple contract types. The government requires employees who are working in certain positions to have specific training for those positions. We are required to re-train annually. On some of our contracts we are authorized reimbursement for this training as a direct charge expense and the contract ceiling allows enough for our company to bill these costs. On other contracts - the costs for this training was not proposed and we have tracked these costs as non-billable to track them against the appropriate objective. Our controller would like to record the costs of the training courses (on the projects we cannot bill because of ceiling restrictions) as overhead items as employees who take these courses could use this training to support other projects if needed. Based on FAR 52.203 ( I believe we are limited to either recording these costs as direct or indirect not alternate based solely on whether we can bill or not. I also believe that as these employees take this training in support of a specific contract that these costs are allocable to a single cost objective and am not sure how we could justify charging them across all contracts. I would like to know if anyone else has ideas as to how we can handle/adjust these costs or good documents to argue my position to the controller. Thoughts??