The sponsoring institution (the university) is required to provide the
interpreter, and the Americans with Disabilities Act makes it clear that
the costs of accommodations for persons with disabilities is an
administrative cost, part of the overhead.

Institutions  have set up internal procedures similar to your
university.  The Disability Services Office usually has a limited
budget  to provide accommodations to "core" services such as the regular
academic program, and also has a coordination responsibility for other
activities and services.  In these cases,  the actual cost of any needed
accommodations is generally charged to the budget for that  activity.
 Grant funded activities are usually not considered  "core" services.

In some institutions the cost of accommodation is always charged to the
budget for the activity, core or not, in order to more effectively track
the actual cost of operation including the requirements to provide
access for persons with disabilities.

Because the probability that there would be a need for these services is
fairly low and relatively unpredictable, I would probably want to
include these costs in the F&A pool, and expense the costs from some
"pooled" account.  If this is the only program that incurs this cost, I
would budget for it as direct, then, if not needed, return it to the
sponsor, or negotiate a "sidebar" agreement with the sponsor that if
needed, these costs will be added to the total costs of the project and
billed accordingly.

Greg & Peg Schmidt

Michael Wetherholt wrote:

> If the award pays the tuition for the attendees, I would think the
> institution should provide the services of an interpreter.
>
> At 03:25 PM 07/18/2002 -0400, you wrote:
>
>> We received private funding (with a 10% administrative fee) to sponsor a
>> summer workshop for teachers.  It is financially self-supporting and
>> attendees get graduate credit.  One of the students is deaf, so our
>> Disabilities Services Office was asked to provide an interpreter (who
>> cost twice what we recovered in administrative fees).  Since this was a
>> self-supporting summer program, we have been asked why the interpreter
>> costs were not built into the grant budget.  (Note that, for our regular
>> academic programs for which students pay tuition, interpreter services
>> are provided by the institution.)
>>
>> Is the interpreter service an indirect cost?  Why would a sponsor--even
>> a private one--want to pay for a service that is normally provided by
>> the institution, unless the funded project is specifically designed to
>> serve persons with a disabiltiy?  If this should have been treated as a
>> direct costs and put in the grant budget, should we start budgeting for
>> interpreter services for all public performances and lectures in case
>> someone with a hearing impairment comes?  How would one ever predict the
>> financial need for that without looking like one is padding a budget?
>>
>> Any thoughts are greately appreciated!
>> Barbara
>>
>>
>> --
>> ==================================================================
>> Barbara H. Gray, Director
>> Office of Research & Grants Administration
>> College of Charleston
>> 66 George Street
>> Charleston, SC  29424
>> Campus Location:  407-G Bell Bldg.
>> Office: 843.953.5673  Desk: 843.953.5885  Fax:  843.953.6577
>> e-mail:  xxxxxx@cofc.edu   URL: http://www.orga.cofc.edu/
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>>
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