We got an interpretation from OPERA re this about a year and a half
ago...and they disagreed...
Even if the cost is listed as potentially allowable in the program
announcement, it is still the institution's responsibility and liability to
assure that the need for the expenditre meets all the allowable cost
requirements. There is no blanket exemption/assumption re allowability for
training programs; no matter what is listed in the program announcement.
There is no presumption of a training program meeting the major projects
criteria.
You could grant an exception to a training award if it is large,
complicated, etc. This assessment must be done on a case-by-case basis.
The fact that training awards have a lot of administrative work associated
with them is not sufficient, in itself. Most training awards would "not"
meet the exception requirements. To grant an exception to a training award
you would have to treat it the same as an R01 and truly make a case that
something extraordinary is going on. A typical T with 5-6 trainees would
not normally reach the bar. A larger training program, with maybe an
international component, multi-degree component, etc., (i.e., more
complications, not just traditional T), might meet the exception
requirements.
-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG]On Behalf
Of Jennifer Shambrook
Sent: Wednesday, February 15, 2006 8:26 PM
To: xxxxxx@HRINET.ORG
Subject: Re: [RESADM-L] Do training grants qualify as a major project?
Two things:
1. Look at the program announcement for your training grant, it may be a
stated allowable expense.
2. If it's not, and the administrative work is a part of the scope of work
outlined in the project, then it probably is allowable.
If you need to soothe some uncomfortable central admin folks who are worried
about audit, clearly write it into your progress report for subsequent years
stating what the person will be doing as a part of the scope of work.
With the trainee recruitment and other issues, there is a great deal of
admin work associated with these and I have frequently seen admin charged as
direct.
-Jennifer
Jennifer Morgan Shambrook, MHA
Associate Chair for Research Administration
Co-Director Division of Public Psychiatry
Department of Psychiatry and Behavioral Science
Medical University of South Carolina
67 President Street, Suite 504
Charleston, South Carolina 29425
voice: 843-792-0191
fax: 843-792-0048
email: xxxxxx@musc.edu
>>> xxxxxx@MAYO.EDU 02/15/06 17:11 PM >>>
Greetings all,
Does your institution consider NIH training grants to be a major project?
If yes, is it an across the board determination? That is, are NIH training
grants always treated as major projects, or is the determination still made
on a grant-by-grant basis?
Specifically, I'm wondering about direct charging administrative and
clerical salaries to NIH training grants. To do so requires some level of
comfort that unlike circumstances exist, but I'm not very familiar with the
level of administrative support required by a training grant versus an R01.
A-122 offers no guidance on what a major project is. I've looked at A-21,
Exhibit C for additional guidance, but am still unclear on whether NIH
training grants would make it through the "major project" gauntlet. I've
searched the archive... no luck. I've searched the web... little luck.
Any help you can provide is appreciated.
Kevin L. Roberts
xxxxxx@mayo.edu
(507) 266-5368
Mayo Clinic
Plummer 5-15
200 1st St. SW
Rochester, MN 55905
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