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
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Andrea Buford
Director, Office of Sponsored Programs
Oakland University
Rochester MI
(248) 370-3789
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Original Message:
Sent: 05-27-2021 14:05
From: Linda Phi-Nguyen
Subject: NIH allowability of costs for student tuition & fees policy
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
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Linda Phi-Nguyen
Research Analyst
University of California, Riverside
Riverside CA
(951) 827-7335
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