I think Megan has it right that you just have to show that the department is "paying" for that portion of the shop rate.  Imagine if you already had a shop fee specified in the tuition for students in that dept. then you could compare the cost and the use against the income to show that the price for anyone is consistently treated.
________________________________________
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> on behalf of Megan Roth <xxxxxx@ACU.EDU>
Sent: Tuesday, August 27, 2019 1:44:03 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Service Fee Question

I think my question is not being communicated clearly. These are not graduate students working on grants. There is no PI to bill. The students are undergraduates in the department who are using the equipment for their undergraduate studies. The department does not wish to bill undergraduate students for equipment usage.

On Tue, Aug 27, 2019 at 2:44 PM Vicky Ortiz Batson <xxxxxx@creol.ucf.edu<mailto:xxxxxx@creol.ucf.edu>> wrote:
In my college at UCF, to use our machine shop, the PI has to provide what account number (for a specific project) to charge the machine shop costs to. It doesn’t matter if the PI is in our college or a different college at UCF.

Thank you.

Vicky Ortiz Batson, MA.
Pre-Award Research Administrator
CREOL, The College of Optics & Photonics
University of Central Florida
Phone: 407-823-6825

From: Research Administration List [mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG<mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG>] On Behalf Of Megan Roth
Sent: Tuesday, August 27, 2019 3:29 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG<mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG>
Subject: Re: [RESADM-L] Service Fee Question

I understand that when we are talking about going across departments. But this is within the department that runs the shop, i.e., the students of the department that runs the shop use the shop. Does the department charge itself for its own students use?

On Tue, Aug 27, 2019 at 2:25 PM Simpson, Gregory <xxxxxx@tufts.edu<mailto:xxxxxx@tufts.edu>> wrote:
Megan,

Normally, there would be an internal transfer of costs between department account numbers, whether or not it is within the same school/dept. or not, much like if your department were purchasing books from the university bookstore or if you were buying copy paper from a copy pool.
--Greg Simpson

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG<mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG>> On Behalf Of Megan Roth
Sent: Tuesday, August 27, 2019 3:03 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG<mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG>
Subject: [RESADM-L] Service Fee Question

Hello,

I am filled with questions this week. . .

We have a department that has a machine shop with a service fee. This is a new area for us. I understand that 200.468(b)(1) requires that we do not discriminate between funding sources, including for internal purposes.
I understand this requirement when we are talking about intradepartmental billing. How do you handle this when the department allows their own students to use the shop for their work? This is part of the department's internal use and a resource for the student's academics. Do we just have to show that the department is "paying" for that portion of the shop rate? E.g., if the students use the shop 10% of the time, the department is footing 10% of the bill? I mean, the department isn't going to invoice itself, right?

--
Megan Roth, Ph.D.
Executive Director of Research
Abilene Christian University
320 Hardin Administration Bldg
ACU Box 29103
Abilene, TX 79699
O: 325-674-2885
F: 325-674-6785
xxxxxx@acu.edu<mailto:xxxxxx@acu.edu>

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--
Megan Roth, Ph.D.
Executive Director of Research
Abilene Christian University
320 Hardin Administration Bldg
ACU Box 29103
Abilene, TX 79699
O: 325-674-2885
F: 325-674-6785
xxxxxx@acu.edu<mailto:xxxxxx@acu.edu>

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Megan Roth, Ph.D.
Executive Director of Research
Abilene Christian University
320 Hardin Administration Bldg
ACU Box 29103
Abilene, TX 79699
O: 325-674-2885
F: 325-674-6785
xxxxxx@acu.edu<mailto:xxxxxx@acu.edu>

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