Phil,

You should be able to charge background checks to grants as long as
institutionally across the board the cost of the background check is not
included as a component of the F&A rate.  Nothing prohibits background
checks a direct cost and some projects require them (usually
non-federal).  I also think the integrity of federal projects benefit
from the charge of a background check.  But the real challenge is the
need to divide a $45 dollar charge consistent with individuals effort
distribution - which sounds to me like more of headache than it is worth
but it is doable.  To be allowable as the cost is a flat per person
cost, the cost of the background check attributed to any particular
grant would have to be consistent with the percent effort being
committed to the grant.

The key issue on allowability of any cost, except for those specifically
identified as an indirect cost in the cost circulars, is consistent
treatment of the cost.  So with that as the basis you can chose to
approach the cost either directly or indirectly and it sounds like WKU
want to charge it to the grants.

If you want additional support as to why it should not be charged to
grants you might should also consider the impact on your F&A rate.  This
is particularly compelling if you are currently in a base year for rate
calculation as you will have campus-wide a notable increase in the F&A
costs with this being a implementation year with the entire campus
undergoing background checks - or does the requirement only apply to new
hires.  Also in including the cost in your F&A rate, the background
check should not be expensed as an administrative cost in the rate
negotiation, but as a plant and homeland security cost, which is not
capped for educational institutions.

For medical schools, which have long required background checks for
their employees, the cost is normally in the indirect cost base - which
is a reasonably logical approach to expensing the cost.  The determining
factor for whether a charge is direct or indirect is driven by whether
the cost is incurred for common or joint objectives and, therefore,
cannot be identified readily and specifically with a particular
sponsored project, an instructional activity, or any other institutional
activity.

Good luck and call if you want to talk about options/approaches.  I
would hate to have to process the costing logic for proportional
distribution of such a small amount of money.

Kris

_________________________________________
Kris Rhodes MS, CRA
Director, Grants Administration
Wake Forest University Health Sciences
Phone:  336-716-3019

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Phillip Myers, Ph.D.
Sent: Thursday, July 27, 2006 3:11 PM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] Paying for background checks for grant funded
personnel

Just recently our school has created a policy derived from state
regulations that background checks must be performed on all new hires.
The institutional policy requires that grants pay for grant funded
personnel. Since we have over 500 of these folks on the campus with more
to be hired we are going to run into this issue time and again. I guess
that in these parts the outsource that will perform the checks will
charge $45 per check. Well obviously we can't charge the grant for this
and it is not a part of our indirect cost base.

We're trying to resolve this issue, and would like to know if any of you
have run into this matter and if so how you resolved it.

Thanks for your advice,

Phil

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 subscription information and a web-searchable archive, are available
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