We have been having this problem since late spring/early summer and the reason given is the ACA. We had two students participate in an REU site at another institution in our state but they were funded under a RUI awarded to our of our PIs. When we tried to process their stipends through payroll (how it had always been done), our controller questioned it and sent it over to HR. We had a rather lengthy and warm (not quite heated) email discussion, with HR insisting that the students were providing a service and had to be paid as employees, even stating that the HR department at the other university could take care of our HR requirements (orientation and the like) since our students were not on campus. By this point we were several weeks beyond the time which we should have paid the students, so they set them up as employees and paid them that way.

The situation has persisted with HR wanting to pay other participants in programs here as employees. I have too many fires to fight at the moment, but this “fight” is not over. I contacted NSF because I was hoping they might say that we can’t use participant support stipends to pay an employee (per the PAPPG) — and this would give me powerful ammunition — and they are looking into it, but I need to provide more information to them (and the aforementioned fires have delayed me doing this).

Has anyone else contacted NSF about participant support being used to pay employees (what the university is calling employees, mind you)? I would love to hear if others are having these issues.

Carolyn

Carolyn E. Elliott-Farino
Executive Director, Office of Research
Kennesaw State University &
Kennesaw State University Research and Service Foundation
Room 3413, MD 0111
585 Cobb Avenue
Kennesaw, GA 30144
www.kennesaw.edu/research

> On Oct 27, 2015, at 9:23 PM, Frederick, Jackie A. <xxxxxx@WRIGHT.EDU> wrote:
>
> Hollie,
>
> Can you tell us how your stipends are paid out - through payroll or which department?
>
> Jackie
>
> Jackie Frederick
>
> Director, PreAward
>
> Wright State University
>
> 201J University Hall
>
> Dayton, OH  45435-0001
>
> Voice: 937-775-2664 - Fax: 937-775-3781
>
> email: xxxxxx@wright.edu
>
> ________________________________________
> From: Research Administration List [xxxxxx@lists.healthresearch.org] on behalf of Schreiber, Hollie [xxxxxx@OKSTATE.EDU]
> Sent: Tuesday, October 27, 2015 5:51 PM
> To: xxxxxx@lists.healthresearch.org
> Subject: Re: [RESADM-L] NSF participant support costs
>
> Lori,
>
> We had some growing pains with our recent REU site grant.  We went back and forth between stipend and temporary employee, and actually got as far as creating an employment action to set them up as temporary employees – which would have ended up a disaster.  We reversed direction and paid it all out as stipends/participant support costs.  It worked well.
>
> When we got all the involved parties in a room to discuss it,  a couple of points made it clear that stipend was the way to go.  1) They are not our employees, or even our students. They are participants in a research program. 2) They are not working for us. They are here to learn. 3) If they were paid as temporary employees, the amount of money each student would receive would be reduced due to applicable taxes and other fringe benefits.
>
> We did not encounter any ACA issues, however, in our discussions.
>
> Hollie
> Hollie Schreiber, MBA, CRA
> Manager, Sponsored Programs Administration
> Division of Agricultural Sciences and Natural Resources
> 243 Agricultural Hall
> Stillwater,  OK  74078
> (405) 744-7196; (405) 744-8863 fax
> [cid:image001.gif@01C9F343.FA62D7F0]
>
> CONFIDENTIALITY NOTE:  This e-mail communication and any documents, files, or previous e-mail messages attached to it may contain confidential information.  If you are not the intended recipient, or an employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited and unauthorized.  If you have received this communication in error, please immediately notify the sender by return e-mail and delete this communication and all copies and backups thereof.
>
> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Messer, Lori
> Sent: Tuesday, October 27, 2015 3:35 PM
> To: xxxxxx@lists.healthresearch.org
> Subject: [RESADM-L] NSF participant support costs
>
> Is anyone having challenges at their institution (for example with HR) related to paying NSF participant support costs?  We have a REU Site grant and have been told by HR that participants had to be hired as temporary employees due to the Affordable Care Act.  The participant support costs were budgeted as stipends, not salaries, so we are trying to get clarification from our HR Dept about this.  In the meantime I was just wondering if this has come up elsewhere.
>
> Thanks,
>
> Lori
>
> --
> Lori Messer, CRA
> Director
> Research & Sponsored Programs
> Wake Forest University
> P.O. Box 7528
> Winston-Salem, NC 27109-7528
> xxxxxx@wfu.edu<mailto:xxxxxx@wfu.edu>
> (336) 758-5888
>
> Follow us on Twitter @WFUResearch
>
>
>
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