Let me ask you a question: could the teachers have attended the training if
the school system had not found substitute teachers to take their classes? I
would postulate that this expense did directly benefit the project. We have
budgeted and paid substitute teacher pay on similar projects.

You say that this was written into the proposal and approved by NASA. Did
the justification explain that the pay was for substitute teachers so your
trainees could attend your workshop? If so, I think this would be an
approved expense.

Who submitted the proposal? Did it go through your sponsored projects
office? Did you speak with them? What is your role in this?

Carolyn Elliott-Farino, MA, CRA
Director, Contracting and Grants Administration
Office of the Vice President for Research and Graduate Dean
Kennesaw State University, 1000 Chastain Road, MD 0111
Kennesaw Hall, Room 3419 (deliveries), Kennesaw, Georgia 30144-5591
Direct: 770.423.6381;Main line: 770.423.6738
xxxxxx@kennesaw.edu; www.kennesaw.edu/ogc

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-----Original Message-----
From: Research Administration List
[mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Sandy Shriver
Sent: Thursday, November 10, 2011 10:40 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Indirect Payment?

I have an issue with one of our federal grants on a proposed expense.  The
PI has a training at which County School Teachers attended.  The PI cannot
pay the teachers a stipend to attend since they attended on a regular
workday and this would be double-dipping.  However, the schools had to hire
substitutes for the regular teachers who went to the training.  And the PI
wants to pay the County Schools the cost of the substitutes and said that it
is done on federal awards all the time and has been done by other state
higher ed institutions of which she is aware.

I said that this is an unallowable cost because we cannot pay the salary of
the substitutes since they did not directly serve the purpose of the grant.
The PI believes that it is allowable because it was written into the
proposal and approved by the granting agency (NASA).  I maintain that it is
still unallowable per A-21, J.10. which states "Charges to sponsored
agreements may include reasonable amounts for activities contributing and
intimately related to work under the agreements..." And we have to meet the
requirements of the OMB and A-21 to ensure compliance for audit purposes.

Anyone have any thoughts on this?  Just want to clarify if I am on the right
track or not.

Thank you,
Sandy Shriver
Office Administrator Sr.
Fairmont State University
1201 Locust Avenue
Fairmont, WV  26554
304-367-4684 (phone)
304-367-4850 (fax)
xxxxxx@fairmontstate.edu

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