Pat's answer is excellent. I add the obvious: in the specific case of a
background check required by the sponsored program that is not routine for
the institution to perform for other employees it is absolutely an
allowable cost. You should know of this requirement before preparing a
proposal, so be sure to budget for that cost.
Chuck
At 04:00 PM 7/7/2004, you wrote:
>This is a good question, and you may get some different answers.
>
>Here’s my take on this: I believe the more important issue is treating
>non-sponsored and sponsored department hires in a consistent manner. The
>rationale of it not being appropriate as a direct charge because the new
>hire could go on to work elsewhere in the institution (sponsored or
>non-sponsored) can go both ways; an individual could be hired on
>university funds and then go to work on a sponsored project at a later
>date. How would you handle position advertisements (e.g., classified ads)
>for a sponsored project hirethis situation sounds like a good corollary
>to that and you could follow that model.
>
>Regardless of how you do it, it would probably be a good idea to cover
>treatment of this in your policies/procedures for direct/indirect charging
>as well as your DS-2 so that it’s clear to the Federal government that
>you’re meting CAS 502 – consistency in allocating costs incurred for the
>same purpose by educational institutions.
>
>I wouldn’t say that you get no reimbursement at all if you treat it as an
>indirect cost. It just goes into the portion of the F&A rate that has the
>26% cap.
>
>Pat
>
>Patricia A. Hawk
>Cost Analyst, Business Affairs
>Oregon State University
>306 Kerr Administration Building
>Corvallis, OR 97331
>(phone) 541-737-9585
>(fax) 541-737-2069
>
>
>----------
>From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf
>Of Vigiolto, Margaret
>Sent: Wednesday, July 07, 2004 11:46 AM
>To: xxxxxx@HRINET.ORG
>Subject: [RESADM-L] Background checks
>
>I’ve received a request from our HR group to charge background checks for
>new employee hires to sponsored project funds. This is consistent with the
>way it is handled for regular non-sponsored department hires.
>
>I’m struggling with the direct charge idea because of the budget
>implication on the front end and the thought that it may not be exactly
>appropriate to charge one project when the new hire could go on to work on
>other projects in the future. On the other hand, we get no reimbursement
>at all if we treat it as an indirect cost since admin is capped. Are other
>institutions handling this by direct charging or including the cost as a
>component of the indirect cost rate?
>
>Many thanks for this group!
>
>Peggy Vigiolto
>Associate Vice Provost
>Office of Research and Graduate Policy
>Drexel University
>3201 Arch Street, Suite 100
>Philadelphia, PA 19426
>215-895-2311
>215-895-6699 fax
>xxxxxx@drexel.edu
>
>
>
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Herbert B. Chermside, CRA
Special Asst. to VP-Research
Virginia Commonwealth University
PO BOX 980568
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Voice: 804-827-6036
Fax 804-828-2051
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