We had a similar condition at the University of Minnesota.
1) Our local International Student Services (ISS) office transformed itself from a centrally funded unit into a "service center" (due to cost considerations). The question arose about ISS starting to direct charge grants for visa/other processing costs involving those few foreign graduate students, who might work on sponsored agreements during their stay.
2) Since the overwhelming majority of ISS costs relate solely to visa
processing are for undergraduates simply taking courses, we mandated against
direct charging to sponsored agreements. That is, we adhered to consistent
charging of these as "normally" indirect type costs (see A-21, sections
F6b and F9a). Also, we felt that such was in compliance with the
federal "consistent treatment" cost accounting standard (CAS 502 -- see
A-21, section C11).
http://www.whitehouse.gov/omb/circulars/a021/a021.html
3) In truth, the dollar amounts involved are immaterial and would not impact our F&A rates calculation. Also, the broad, generic narratives in our federally approved Disclosure Statement, DS-2, obviously did not specifically mention this very small service center.
4) However, we still felt it necessary to enforce compliant costing
mechanisms to avoid inconsistency costing which may have been pernicious
to the overall F&A negotiations if detected by federal auditors.
Please note that the federal auditor F&A Proposal review guide specifically
mentions such (see page 19).
http://rates.psc.gov/lfrevugd1.pdf
I hope that my response is of some benefit.
Regards,
Steve
===========================================================
Amy Hibbard wrote:
Hi there-
I have a PI who wants to know if he can charge the visa fees for a foreign
postdoc he wants to hire to his NIH grant. My instinct is no, but I'm
having trouble finding the regulation that spells it out. Does anyone have
a reference for this in the NIH grants policy statement or an OMB circular?
Thanks,
-AmyDiscovery consists in seeing what everyone else has seen and thinking what
no one else has thought.
-Albert von NagyrapoltAmy Hibbard
Grants Administrator
Keck Graduate Institute of Applied Life Sciences
535 Watson Drive, Claremont, CA 91711
T: (909) 607-9313 / 607-7855
F: (909) 607-8086
xxxxxx@kgi.edu
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