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Grant Question of the Day Archive

Q: I have a PI that wants to pay instructors (non U of C people) for their participation in a workshop under participant support costs. This is in addition to paying for their travel related expenses. I disagree. I sent a note to Controllers and URA last week but they are strangely silent on the matter.

A: Here's my reasoning as to why it can't be paid under participant support costs:
  1. 1) In order to get paid a stipend, they need to be registered students. These clearly will not be registered students.
  2. 2) In order to get paid they need to either be on the payroll (making them an employee) or on a DPV, making them a consultant.
  3. 3) Any stipend under participant support costs is used to cover living expenses, and not be a form of income. From the manual:
    To help defray the costs of personal maintenance while participating in a conference or training activity, participants may be paid a stipend, per diem or subsistence allowance, based on the type and duration of the activity, as outlined in the pertinent program solicitation and in the grant. Such allowances must be reasonable, in conformance with the usual policy of the grantee organization and limited to the days of attendance at the conference plus the actual travel time required to reach the conference location by the most direct route available. Where meals or lodgings are furnished without charge or at a nominal cost (e.g., as part of the registration fee), the per diem or subsistence allowance will be correspondingly reduced. Although local participants may participate in conference meals and coffee breaks as provided for in GPM 625, "Meetings and Conferences," grant funds may not be used to pay per diem or similar expenses for local participants in the conference.
Additional compensation beyond the costs of participation such as transportation, lodging, subsistence allowance (meals and incidentals), or registration fees are not allowable. Participant support can be budgeted by line item, as a general travel allowance, or even a per diem participation stipend depending on the preference of the funding source.
It is generally a good idea to create an associate account to track participant support costs separately.

Q: Do post-doctoral NSF fellowhips need to be routed through URA?

A: I've seem them done both ways - some were routed thru URA & some Fellows submitted theirs directly to NSF.
By the way, the Post-Docs that went directly to NSF (came in after the fact) with Host-Institutional Allowances which were awarded...
So my answer is "Yes" & "No"
If in doubt, ask URA

Q: What is the difference between a subcontract and a cooperative agreement?

A: Subcontract is spelled with 11 letters and cooperative agreement has 20 :) ha ha ha...
The question, should be, what's the difference between grants & cooperative agreements? (A subcontract would be a contractual/legal agreement between the prime awardee and another organization in which the subcontractor agrees to perform some of the work of the research project.)
NSF generally utilizes grants in support of research and education in science, mathematics, engineering and technology. In cases where assistance projects require substantial NSF technical or managerial involvement during the performance period, NSF uses cooperative agreements. both types of assistance awards, cooperative agreements may include different or additional requirements.
A GRANT is a type of assistance award and a legal instrument which permits an executive agency of the Federal government to transfer money, property, services or other things of value to a grantee when no substantial involvement is anticipated between the agency and the recipient during the performance of the contemplated activity. Grants are the primary mechanism of NSF support.
A COOPERATIVE AGREEMENT is a type of assistance award which may be used when the project being supported requires substantial agency involvement during the project performance period. Substantial agency involvement may be necessary when an activity: is technically or managerially complex; requires extensive or close coordination with other Federally supported work; or helps assure suitability or acceptability of certain aspects of the supported activity. Examples of projects which might be suitable for cooperative agreements are systemic reform efforts, research centers, policy studies, large curriculum projects, multi-user facilities, projects which involve complex subcontracting, construction or operations of major in-house university facilities and major instrumentation development.
Cooperative agreements will specify the extent to which NSF will be required to advise, review, approve or otherwise be involved with project activities, as well as require more clearly defined deliverables.

More than you ever wanted to know:
Although active NSF involvement usually takes place may be necessary under cooperative agreements, awardees still have primary management responsibility for conduct of their projects. To the extent that NSF does not reserve responsibility for coordinating or integrating the project activities with other related activities or does not assume a degree of shared responsibility for certain aspects of the project, all such responsibilities remain with the awardee. As appropriate, NSF may provide advice, guidance or assistance of a technical, management, or coordinating nature and require NSF approval of specific decisions, milestones, procedures or subawards. While NSF will monitor cooperative agreements, it will not assume overall control of a project or unilaterally change or direct the project activities. All cooperative agreements will state the nature and extent of expected NSF involvement to ensure that the responsibilities of each party are fully understood.

Q: Are cellphone and internet charges allowable on federal grants?

A: Yes, but the PI needs to be able to make a plausible argument that the phone/internet connection will be used exclusively for the project (e.g. someone doing fieldwork might need a cell phone). Obtain, prior agency approval for the charge. If at all possible, put the charges on a Ledger 2 account.

Q: PI asks, "I'll be in Podunk over the summer on a personal trip, but I'll need to return to Chicago for a few days to collaobrate with a collegue. Is it OK to use my NSF grant to cover my airplane ticket for Podunk-Chicago-Podunk?" Well, can he?

A: When you are on assignment at a work location more than 50 miles from both home and official station you are considered to be in travel status. This determines that you are eligible for reimbursement of travel expenses such as meals and lodging. So, it is not an allowable grant expense because we would not charge a grant for the cost of commuting from home or vacation (non-work locations) to work.

Q: A professor is building a highly radioactive watchamacallit in the high bay. The odor is terrible and potentially lethal, but the extremely dedicated staff stay at their desks and continue to work. Several will later fall ill and die, but that's beside the point. In addition to the equipment costs, the professor hires a technician and an engineer to work on the project. Are their salaries considered constructed equipment?

A: The short answer is, no. According to University policy only shop charge labor services can be included as part of a fabricated equipment expense, other University labor is excluded. The hired technician and engineer should be treated like any other University employee (temporary or otherwise) working on a sponsored award.
However, if assembly/installation of purchased equipment was included in the cost of acquisition and the vendor's technicians, or their subcontractee, were assembling the equipment, then that kind of labor could be expensed as "fabricated equipment" (see NSF 07-140 chapter 5.B.2.b.i). By the same token if a company/private subcontractor were hired specifically for the purpose of assembling fabricated equipment (and absolutely nothing else), then that kind of expense could be under constructed equipment since they are not University employees and the scope of the job is strictly confined to the construction of equipment.
If the hired technician and engineer were in fact building themselves into the equipment creating some kind of cyborg entity, then they could be expensed as constructed equipment, at least until they are subsumed by the collective consciousness of the machine. Then again, there would probably be some human subject protocols to clear first.

Q: Suppose you have an NSF grant that has been closed for one year. Out the blue, the payroll department calls and says that due to the comptroller's office error, you will be receiving a $10,000 credit on the account and asks where to apply the credit. You blink once, you blink twice. The comptroller's office made an error? Impossible, you think. The comptroller's office explains it wasn't really their fault, but that of incompetent departmental administrator. Thank goodness the natural laws of the universe are still in force. But still there's a credit. What do you do?

Q: Suppose an NSF cooperative agreement requires an external advisory board (EAB). Are the travel costs of the board members to UChicago's campus allowable on the agreement? What if the cost was not included in the agreement budget, nor discussed in the project description?

A: Consult the program announcement and the award letter to be sure about how the EAB is to be handled. If the EAB is mandatory, then it is reasonable to request funds to reimburse its travel expenses in the budget. If it was left out of the budget by accident, it would be prudent to either rebudget (with agency approval if needed) to accommodate the reibmursements or request additional funds from the agency.

Q: One of the recharge trucks gets a parking ticket (from the University, no less)! How do we pay the parking ticket and on what account?

A: It's an unallowable cost. It must be paid from a 2-ledger (not a recharge account) or 4-ledger account using the unallowable cost subaccount for fines (99xx).

Q: What if the recharge's truck was parked next to its own loading dock when it was tickted?

UChicago Police: Oh alright, we'll drop the ticket this time. But you need to get a monthly parking pass to avoid another one.

Q: Can a U of C faculty member hire a faculty member at another university as an independent contractor (for scholarly research collaboration) on a 2-ledger account and pay the other university directly rather than the faculty member? Let us just assume that the other university has no problem hiring out its faculty like this.

A: Yes, if you set him up as an independent contractor.

Q: OK, it seems easy so far. Now, one more wrinkle... What if the two faculty members in question are related (sibling, parent, spouse, child, etc)? Does that add any conflict of interest hoops to jump through?

A: Hmm, sounds inappropriate. Ask the PI to review the University's conflict of interest policy (COIP) and follow the approval tree in the COIP or at a minimum discuss with his/her department chair to get it on record.

Q: Should a pre-proposal be listed in the current and pending?

A: Considering that it is an outstanding request for grant funding, yes it should be included. A preliminary proposal will generally have budget information and a statement of work, so that information can be applied to a current/pending report. Like a full proposal it is evaluated as part of the competitive selection process that can ultimately result in an award.
>A letter of intent, on the other hand, contains little to no budgetary info, no formal statement of work or full project description, and generally has no bearing on the selection process on the part of the funding agency. So a LOI should not be in a current and pending report.

Q: What about a full proposal with no budgetary info (such as an incoming subaward with a TBD budget)? How would you list it?

A: Any full proposal should be on a current/pending report even if there is no final budget. If an incoming subaward, a best guess based on the maxium amount the prime can be used in lieu of real figures. Or just indicate that the budget is TBD if budgetary figures are truly unknowable at the time. A current/pending report will need to be amended from time to time (budget revisions, rejected proposals, etc), so at best it can only be a momentary snapshot of one's funding situation as best understood at the time.

Q: Suppose you have a grant that allows salary but not fringe benefits. Since the fringe is automatically calculated, how would you remove the benefit cost?

A: Contact Comptroller's Office, aka Finanical Services, first (Gayle Orlando). You will need an offset account to pay the fringe.

Q: The University can reimburse Economy Plus upgrades, but can these upgrades (as well as any other airline and/or rental car upgrades needed to accommodate medically, physically, or vertically challenged individuals), after receiving the Dean's Approval as a necessity, be charged to a 5-ledger grant account?

Yes, it can be charged to a grant if it is fully documented that the travel was necessary for the award and that the traveler simply could not complete the travel without the special accommodation due to a physical or medical disability of some kind (see CFR §200.474 effective 12/26/2014).
Circular A-122, section J, chapter 48, paragraph C does allow for exceptions to the "lowest available commercial discount airfare" rule if the exception is fully documented by the institution that such a fare is "unavailable". Medical needs are an acceptable reason. (see below)
"Airfare costs in excess of the lowest available commercial discount airfare, Federal Government contract airfare (where authorized and available), or customary standard (coach or equivalent) airfare, are unallowable except when such accommodations would: require circuitous routing; require travel during unreasonable hours; excessively prolong travel; greatly increase the duration of the flight; result in increased costs that would offset transportation savings; or offer accommodations not reasonably adequate for the medical needs of the traveler."
Furthermore, based on the non-discrimination rules in U.S. Code (title 29, chap. 16, sec. 794) a qualified person (in this case a participant on the grant) cannot be denied participation in or the benefits of any activity [the grant in question] funded by the federal government. NSF adheres to this rule.
The key here is to fully document why the upgrades or special costs were needed (not simply desired) for medical reasons. So if documentation cannot be obtained, then you could try charging the original airfare (minus the upgrade) to the grant, and then charge the cost of the upgrade to an unrestricted account. This assumes, of course, that the upgrade costs can be separated.

Q: Now I'm curious whether or not the Dean will approve reasons such as "being too tall for a coach seat" or "being too short to reach the pedals/see over the dashboard"--both of which are ACTUAL explanations provided by individuals on reimbursement requests.

A: Good Luck on thait one.

Q: A faculty member has a 7 ledger block fund. Someone in the Deans office wants to add money based on a previous commitment. Can she transfer money from a 2 ledger to a 7 ledger?

A: No. 7-ledger accounts should have descrete sources of revenue (endowment income, interest, etc.) and are given for a designated purpose (even if there are no formal spending restrictions). Those defined income streams should not be co-mingled with unrelated informal or ad-hoc transfers from other accounts. Especially so if the block fund is to be understood as an internally funded grant.
If the Dean's Office promised unrestricted start-up funds (or something similar) a separate 2-ledger account for that purpose should be created.

Q: Does anyone know if charges for advertising a job (post-doc) are an allowable expense on a NSF award?

A: Yes it is. See OMB circular A-21 excerpt below (see CFR §200.463 effective 12/262014)...

c. The only allowable advertising costs are those which are solely for:
(1) The recruitment of personnel required for the performance by the institution of obligations arising under the sponsored agreement, when considered in conjunction with all other recruitment costs, as set forth in Section J.37 [of circular a-21];
(2) The procurement of goods and services for the performance of the sponsored agreement;
(3) The disposal of scrap or surplus materials acquired in the performance of the sponsored agreement except when institutions are reimbursed for disposal costs at a predetermined amount in accordance with Circular A-110; or
(4) Other specific purposes necessary to meet the requirements of the sponsored agreement.

See the recruiting specific guidelines...
37. /Recruiting costs/.
a. Subject to subsections b, c, and d, and provided that the size of the staff recruited and maintained is in keeping with workload requirements, costs of "help wanted" advertising, operating costs of an employment office necessary to secure and maintain an adequate staff, costs of operating an aptitude and educational testing program, travel costs of employees while engaged in recruiting personnel, travel costs of applicants for interviews for prospective employment, and relocation costs incurred incident to recruitment of new employees, are allowable to the extent that such costs are incurred pursuant to a well-managed recruitment program. Where the institution uses employment agencies, costs not in excess of standard commercial rates for such services are allowable.
b. In publications, costs of help wanted advertising that includes color, includes advertising material for other than recruitment purposes, or is excessive in size (taking into consideration recruitment purposes for which intended and normal institutional practices in this respect), are unallowable.
c. Costs of help wanted advertising, special emoluments, fringe benefits, and salary allowances incurred to attract professional personnel from other institutions that do not meet the test of reasonableness or do not conform with the established practices of the institution, are unallowable.
d. Where relocation costs incurred incident to recruitment of a new employee have been allowed either as an allocable direct or F&A cost, and the newly hired employee resigns for reasons within his control within 12 months after hire, the institution will be required to refund or credit such relocation costs to the Federal Government.

Q: Two UChicago PIs would like to participate on an NSF grant being submitted by another university. The UChicago PIs will not receive any research support or salary support. Is involvement by either URA, PSD Dean's Office or home department required?

A: The key issue is whether they should be recognized as senior personnel or casual collaborators. If the latter, then they should not receive any suppor, and thus no URA involvement is needed. As far as I know, faculty can talk to whomever they want about whatever they want without needing approval from URA. They could have regular meetings if they want so long as they have no formal role in the project (or in the proposal for that matter). As an analogy, an author could rely on a former professor to read multiple chapters of his book, provide comments, and offer ideas for free as a result of their personal relationship however this doesn't mean his professor is entitled to co-authorship credit or any formal acknowledgment beyond a voluntary thanks in the preface.

If they are to be understood as being senior personnel, consultants, etc. then they should have a defined role in the proposal and their participation should be duly noted in their current/pending files. Senior personnel cannot have 0% effort. Hence we have one of the dreaded cost-sharing scenarios, of the voluntary committed variety. If it is an NSF project, then they must take salary because cost-sharing is prohibited. Such a case would need to go through URA and the various approval layers. This then raises the issue of how the proposal is submitted. Should it be a collaborative proposal (ala NSF), subcontracts of some kind, temporary joint appointments with the other institution? Somehow, their formal participation and resulting effort will need to be documented either here or at the other institution.

Q: How would you budget a post-docs institutional allowance, assuming the allowance was going to be used for Garnett-Powers health insurance.

A: The way this normally works is that the fellow receives their normal fellowship plus the cost of benefits in their pay. Garnett-Powers will then deduct the amount of the benefits that were elected which should result in the fellow receiving their original stipend amount.

For example if a fellow is to receive a stipend for $3000 per month but wants health coverage you should pay him/her the stipend amount plus an additional $300 per month for the insurance premiums. GP will then deduct the $300 from their stipend during the payroll process leaving the fellow with the remaining $3000. When a fellow is receiving a stipend through the UofC the benefits should not be paid through an interdepartmental order (IDO).

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