I would use the old “but for this project, this expense would not be incurred” argument and allocate it in the same distribution as the initial payroll. I don’t often see background checks on grants because many of the people working on them have already been working somewhere else on campus.

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Jason K McCrory
Sent: Thursday, May 19, 2011 2:09 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Pre-employment background investigations

Assuming it isn’t included in the F&A rate and is allowable, how are you going to allocate the expense? If the person is 100% on one funding source, fine. But if not, are you planning on allocating based on effort? If so, based on what reporting period?

Jason

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Scott Niles
Sent: Thursday, May 19, 2011 2:19 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Pre-employment background investigations

Andrea,

My initial inclination is to say it isn't a direct cost, as these sorts of HR costs may be built into your institution's F&A calculation. You may need to check with your accounting folks to confirm that. However, since you said this was a new policy, it may not have been factored in , and you might be able to make a case for their inclusion.

I'm sure others will have some great info for you.

Best of luck,

Scott

Scott Niles, MA, CRA
Grants and Contracts Administrator
Office of Research and Sponsored Programs
Morehead State University
901 Ginger Hall
Morehead, KY 40351
Phone: 606-783-2278
Fax: 606-783-2130
Web site: http://www.moreheadstate.edu/research

From: Andrea Buford <xxxxxx@NIU.EDU>
Reply-To: Research Administration Discussion List <xxxxxx@lists.healthresearch.org>
Date: Thu, 19 May 2011 15:14:13 -0400
To: "xxxxxx@lists.healthresearch.org" <xxxxxx@lists.healthresearch.org>
Subject: [RESADM-L] Pre-employment background investigations

Since January 1, NIU's Human Resource Services has been requiring pre-employment background investigations "for all faculty, supportive professional staff, civil service, and extra-help positions" at NIU. The policy does not normally include graduate assistantships and student employment positions unless they are designated as security-sensitive.

Quite recently, a faculty member wanted to hire a graduate research assistant on a grant (as extra-help) and was told that she'd have to wait until a background check had been completed. Apparently, HRS is using an outside firm to conduct the investigations; the fee for the basic one is $40 a pop. I've looked through A-21, and there isn't anything in there that specifically addresses costs for background checks. Section J.35 (Plant and homeland security costs, since the background rationale for requiring these investigations is the Campus Security Enhancement Act) and Section J.42 (Recruiting costs) make me think that the charge might be allowable as a direct cost on grant budgets.

We budget similar background checks when our faculty and students are working with the K-12 educational system, but those situations involve work with minor children. Perhaps the situation is directly comparable, but it does not seem quite the same to me.

So, in short, do you budget for these costs at the pre-award stage? As always, thank you for wisdom!

Andrea Buford

Research Development Specialist

Office of Sponsored Projects

Northern Illinois University

Office: 815-753-9283

Google Voice: 815-617-9743

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