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  • 1.  NIH allowability of costs for student tuition & fees policy

    Posted 05-27-2021 14:05
    Hello All,

    I am wondering if anyone has requested tuition & fees for grad students to be fully reimbursed by NIH as a form of compensation, in lieu of salary?  For example, if the student is working on an NIH and private grant simultaneously, and the private grant does not allow for tuition & fees, are we allowed to charge that to NIH?  How does this apply to the following NIH allowability of costs/activities policy in this case?  Has anyone come across this before?  Any advice/guidance is appreciated!

    Thank you,

    Linda Phi-Nguyen
    Research Analyst
    University of California, Riverside
    Riverside CA
    (951) 827-7335

  • 2.  RE: NIH allowability of costs for student tuition & fees policy

    Posted 05-27-2021 14:14
    This is a really great question, Linda. I'm going to share this with some folks, but in the meantime I hope other members of the community will jump in!

    Simon Helton
    Community Manager
    Portland OR

  • 3.  RE: NIH allowability of costs for student tuition & fees policy

    Posted 05-28-2021 03:58
    There are a few layers as to how to think about this.  You have to be super-sure that the scopes of the two awards are sufficiently overlapping that sharing costs in this way is ok.  PIs tend to think of their research as one big project - which is really how it is.  And there's a grad student puttering around, learning, contributing.  They tend NOT to think, "from 9-11:30, I am working on Project A and from noon-3 I'm working on Project B."  But grant award do force them to separate out a little.  It would NOT be ok to put any compensation for the student on one project when in fact she's working on an unrelated project.  And this kind of distinction is hard to maintain.  It's not allowable, for instance, for PIs to be awarded from two sources simultaneously for absolutely identical projects - so undoubtedly you created some intellectual distance between them to stay on the right side of this line.

    And, costs for the grad student on the NIH award can only pay her for the time she spends on that award.  So if she's authentically working on both projects, I don't see how she could or should receive full-time tuition remission attached to the one award.  Your effort reporting will be all messed up if you do that.

    That said, if you're going to treat this budget line as salary (meaning putting it in that section of the budget and tracking the costs that way) then it will have to BE salary.  Fringe benefits will be taken out and F&A will accrue - and it will go to the student as salary.  She will have to pay taxes on it (maybe) and can use it for anything she wants - a new washing machine, a trip.  Or tuition, sure.  But your control over the expenditure is gone.  We are all perfectly entitled to spend salary however we like, right?

    If you put it in the tuition line, absent a stipend, that will look weird, for sure.  But not toxicly weird.  You can explain it in the budget justification.  Don't quantify it, or even identify the source - otherwise you've committed cost-share and who needs that?  But again, only tuition aligned with the effort she will spend on that project.

    Or, that's what I'm thinking while I'm having my first cup of coffee.


    Andrea Buford
    Director, Office of Sponsored Programs
    Oakland University
    Rochester MI
    (248) 370-3789

  • 4.  RE: NIH allowability of costs for student tuition & fees policy

    Posted 05-28-2021 07:03
    Hi there,

    Separating the layers here,  yes Tuition remission as part of a Fringe benefit of the student is an allowable cost charged against an NIH grant. However, based on the second part of your question, if the student is working on multiple projects, only the portion of her/his tuition directly proportional to their time working on the NIH award would be chargeable to this grant. It may not be that black and white, but aligns with the cost principle of Allocability. I do see how it would be easy to get caught up in the concept that the tuition will get charged regardless and a need to recover funds from an outside source, but that's where handling cost allocations consistently, regardless of source, also factors into consideration on allowable recovery from one or more federal sources.

    Hope that helps,

    Carolyn Dawson
    Research Administrator
    Regenstrief Institute
    Indianapolis IN
    (317) 560-2096