Thanks Katie, that helps.  Classification schemes are useful, but some of our most profound mistakes are made with classification.

It seems that the issue generally involves where to put employees who have different roles and/or measurable effort.  I did find this specification in General Instructions for NIH and Other PHS Agencies - NIH OER . . .

"Consultants designated as senior/key persons in the Senior/Key Person Profile Form can be
included in the "A. Senior/Key Person" section only if they are also employees of the applicant
organization."

The difference between a consultant and a contractor listed with Other Costs might also be defined by these instructions for the justification . . .

"In the budget justification, identify each consultant, the services he/she will perform, total number of days, travel costs, and total estimated costs."

Doug Mounce, Grants & Contracts Manager, 206-839-1787

________________________________________
From: Katie <xxxxxx@BU.EDU>
Sent: Friday, October 18, 2019 3:38:46 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG; dougm (Doug Mounce)
Subject: Re: Definition of Personnel

I didn't see an answer to this yet, so I'll chime in...

I've had some interactions around this topic in the past, and I'm guessing it's not specific to my sponsor. The short answer as I understand it is yes, personnel = employee for the SF424, but also independent contractors aren't ODC.

My understanding is that payments directly to an individual for services rendered can fall into three of the major budget categories, and it's primarily based on taxes:

Personnel - hired as an employee, ie anyone eligible for a W-2.

Contractual - considered to be a contracted service by your institution, i.e. they're determined to be an independent contractor under the IRS definition.

Other Direct Costs - any other payment to an individual. Typically for us the people who are "consulting" that fall into this category are receiving honoraria but other examples would include gift cards/human subjects payments, etc.

***********

In my department a lot of our consultants are sorted by our institution into either employees (typically if it's a significant amount of time/work and they don't perform the same work for multiple other parties) or independent contractors (they do a significant amount of this work and have multiple other contracts). People with a significant role on the project are rarely included under "Other Direct Costs" because they seem to always fall into one of the other buckets.

In the context of the SF424 this has come up for me twice: first, when we've listed people with the title of "Consultant" under the personnel section, because we'd worked with them before and they were considered staff, and the sponsor asked for a correction before issuing an NOA; and second when the FOA had a note that all "individual consultants" needed to be included under "Other Direct Costs" and we had to check to see how that applied to people who Sourcing had determined to be Independent Contractors. In the first situation we actually changed the title for those positions on the budget documents; in the second the GMS confirmed that it was based on our institution's determination and we included a note in the budget justification that explained why there might be a perceived inconsistency.

This isn't official, unified information I've ever seen anywhere, so it's possible I'm missing something. For me this has become one of those weird rabbit holes you sometimes fall down as a DA, so if someone has more information I would love to know.

Katie Walker |  Financial Manager |  Center for Psychiatric Rehabilitation | Boston University

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