You are both correct.

I have seen the cost of cross-departmental consultation budgeted in different ways depending on the specific situation. In some cases, the cost is budgeted as part of the personnel cost with fringe benefit included. The budget justification needs to disclose that the pay is above the employee’s institutional base pay and provide a reasonable reason. There are also cases where an employee (from a different department or different line of work) may be budgeted as a “consultant” for giving a talk or participating in a specific activity. The amount budgeted is usually a couple of hundred dollars. When it comes to the actual payment, our university does not treat the employee as a consultant. Supplemental compensation is used to pay the employee. The fringe benefit cost is applied as well.

I hope this clarifies the situation.

Thanks!

Jing

Jing Liu, CPA

Assistant Director, Sponsored Projects Services

PO Box 210158, Rm 510
Tucson, AZ 85721-0158

Tel: 520-626-6442

Fax: 520-626-4137

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Ehrlich, Tracy
Sent: Friday, February 24, 2017 8:28 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NIH Stipend Question

I believe that according to IRS rules, employees cannot be consultants for their employer. Our institution imposes a rule, which I am told is an IRS rule, that a consultant cannot be employed by the institution in the past year (previous 12 month period from the start of the consultant assignment).

Your situation sounds more like an overload (compensation for additional duties not normally performed by the employee) paid in addition to base salary and which may require agency approval. It is recommended to document overloads in the proposal budget and justification for agency approval of overload payment on the award notice.

Best,

Tracy Ehrlich

Senior Sponsored Programs Manager | University of Miami College of Arts & Sciences

Research Support Services & Administration | Phone 305-284-9246

xxxxxx@miami.edu | as.miami.edu

University of Miami Sig_Line 031015-1

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Kristina Duryea
Sent: Friday, February 24, 2017 9:06 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NIH Stipend Question

Wouldn't the faculty member still have fringe associated with his/her pay since he/she is an employee? If so, not really a consultant.

Kris

Kristina Duryea, MA, GCRA, CRA

Sr. Finance and Grants Administration Manager

Center for Biotechnology

Bioengineering Bldg, Room 201

Stony Brook University

Stony Brook, NY 11794-5280
631-632-8468

xxxxxx@stonybrook.edu

On Thu, Feb 23, 2017 at 6:35 PM, Liu, Jing - (jingliu) <xxxxxx@email.arizona.edu> wrote:

Christine,

I agree with Carolyn’s analysis.

I am guessing your scenario may be what Carolyn described as incidental pay or cross-departmental consultation. If the faculty member you are trying to add to the budget (1) is not the PI or co-PI and (2) is from a different department or the work on the grant is not his or her normal duty, you may budget the faculty as a consultant on the grant and pay supplemental compensation. You do need to clearly disclose the situation in the budget justification.

I hope this helps.

Best,

Jing

Jing Liu, CPA

Assistant Director, Sponsored Projects Services

PO Box 210158, Rm 510
Tucson, AZ 85721-0158

Tel: 520-626-6442

Fax: 520-626-4137

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Carolyn Elliott-Farino
Sent: Saturday, February 18, 2017 8:59 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NIH Stipend Question

Christine,

"I’m asking because the stipend is small and isn’t attached to a number of hours to perform a task, therefore, would not be part of time and effort."

If this isn't going to be part of time and effort, it must be incidental pay -- it is my understanding of 2 CFR 200 that payment to faculty on a federal grant must be tied to time and effort unless it is incidental pay. You will have to disclose in the budget justification that this is supplemental pay for incidental work and state that you are paying a stipend.

However, I don't think that just because the amount is small and isn't attached to a number of hours to perform a task that the work is necessarily incidental. If you have a definition of incidental and this meets that, then I would think you could budget a stipend and explain it in the justification.

Would love to hear what others think. This is always a troublesome issue.

Carolyn

Carolyn Elliott-Farino

Executive Director, Office of Research

Kennesaw State University

xxxxxx@kennesaw.edu; 470-578-6381

From: "Christine Hempowicz" <xxxxxx@BRIDGEPORT.EDU>
To: "Research Administration Discussion List" <xxxxxx@lists.healthresearch.org>
Sent: Saturday, February 18, 2017 10:12:19 AM
Subject: [RESADM-L] NIH Stipend Question

Quick question – may I include the cost of a stipend for a faculty member in my NIH budget or must the person be listed under “salaries?” I’m asking because the stipend is small and isn’t attached to a number of hours to perform a task, therefore, would not be part of time and effort.

Thanks!

Christine Hempowicz, Ed.D., CRA

Director, Office of Sponsored Research and Programs

University of Bridgeport

126 Park Ave., Bridgeport, CT 06604

203-576-4973

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