All good opinions, but I disagree.

If the cost of substitutes is necessary for the teacher's participation and the teacher's participation will benefit the grant, than I'd consider it an allowable direct charge, to be reimbursed to the school.

The "activity" referenced in A21 is not substitute work, but the teacher's participation which is intimately related to the agreement.  Costs that are associated and necessary to that participation are allowable.

Regards,
John

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Sara L Wilhelm
Sent: Thursday, November 10, 2011 11:14 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Indirect Payment?

While you can't pay the participating teachers additional money, couldn't you reimburse the schools for their time (assuming it meets the other criteria to be considered allowable)?  Just a thought. . .

I agree that the cost of the substitutes cannot be a direct charge to the grant.

Sara

Sara L. Wilhelm
Grant Accountant
Frostburg State University
101 Braddock Road
Frostburg, MD 21532
PH. 301-687-7054
FAX. 301-687-4494

-----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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 via our web site at http://www.healthresearch.org (click on the
 "LISTSERV" link in the upper right corner)

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