Sandy,

To me it is an allowable expense for the following reasons:
 1) The teachers would not be able to attend if there are no substitutes
 2) The rate of substitute pay is less than the cost of a teacher
 3) The substitutes would not be needed if the grant did not require the teachers' presence
 4) The cost is reasonable, allocable, allowable and consistently treated.

I have done this at a prior institution and it had no problems.

Cheers,
Rene

----------------------------------------------------
Rene Hearns, PhD (cand), MPA, CRA
Director, Grants and Sponsored Programs
Edinboro University of Pennsylvania
148 Meadville Street
Edinboro, PA 16444-0001
814.732.1052 Telephone      814.732.2611 Fax
Office Hours  8:00 am to 4:30 pm

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Morgan, Kelly
Sent: Thursday, November 10, 2011 11:15 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Indirect Payment?

Sandy,
We have successfully direct charged the cost of a substitute for several Department of Education grants and if I'm not mistaken, NSF as well.  Our justification is that it is a participant support cost and is necessary for the teachers' attendance at the conference/workshop/training that the grant is funding.

Kelly Morgan
Resource Center Coordinator
Office of Sponsored Programs
University of Idaho
208-885-2145 xxxxxx@uidaho.edu

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Shriver, Sandra
Sent: Thursday, November 10, 2011 7:58 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Indirect Payment?

P.S.  I also advised that this expense be posted to the PI's Indirect Costs budget as an indirect expense.  We give the Dean's, Department Chairs, and PI's a percentage of the IDC that is generated on their grant awards.

Sandy Shriver

-----Original Message-----
From: Sandy Shriver [mailto:xxxxxx@FAIRMONTSTATE.EDU]
Sent: Thursday, November 10, 2011 10:40 AM
To: xxxxxx@lists.healthresearch.org
Cc: Shriver, Sandra
Subject: 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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 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help ======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.healthresearch.org (click on the
 "LISTSERV" link in the upper right corner)

 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help
======================================================================