OMB's recent clarification of the allowability of Tuition Remission costs
from sponsored project agreements addressed several issues relating to
taxability and employee status.  It also included the statement:

"(2) Tuition remission and other support are provided in accordance with
established educational institutional policy and consistently provided in a
like manner to students in return for similar activities conducted in
nonsponsored as well as sponsored activities; and ....."

This appears to be a reaffirmation of the A-21 requirement (Sections C10
and C11, and Appendix A (CASB)) for consistency in applying charges to
federally sponsored and to institutional activities.

Some have interpreted this provision as leaving unchanged to prohibition of
charging tuition to Federally sponsored research (not training) agreements
to an extent greater than the corresponding institutional practice with
regard to Teaching Assistants and Graduate Assistants (who perform duties
other than teaching from institutional funds) -- the latter practice at our
institution being to make tuition awards (as opposed to waivers) in an
amount up to full tuition.

A scan of institutional policies and practices on the web has not provided
a clear response to the concern with consistency.

I seek your input on how your institution reconciles charging tuition to
Federally sponsored projects with this interpretation.  It would be helpful
to know the details of your relevant practices.  You may respond directly
to me.  (xxxxxx@notes.cc.sunysb.edu)

Bob Schneider
Office of the Vice President for Research
State University of New York at Stony Brook

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