Can I Charge That?

Below is Stanford's guidance for the most common uncommon expenses individuals ask if are allowable on sponsored projects and how to properly code them.

Whenever making a cost determination, whether at the time of proposal budget development or post award charging, apply the Cost Principles : allowability, allocablilty, reasonableness, and consistency in addition to Order of Precedence.

Bonuses

Membership Dues/Fees

Mobile Equipment / Cell Phones / Cell Phone Stipends

Participant Support Costs (PSC)

Visa Costs

Bonuses

Faculty bonuses are NOT allowable on sponsored projects.

• Faculty bonuses must be paid from non-sponsored funds.
• Faculty bonus ETs 51905 and 51915 are blocked from being charged on all sponsored PTAs.

Staff bonuses may be allowable on sponsored projects.

• Generally, bonuses coded as follows would be allowable for staff on federal and non-federal awards, provided they are not prohibited by the specific sponsor and award (see below table)
• Performance bonuses should be allocated to the project(s) that benefitted from the extraordinary performance.

Post doc bonuses generally may NOT be charged to sponsored projects.

• If the postdoc is receiving stipend, a bonus may not be charged to sponsored projects, including fellowships.

Learn More

View the Bonus & Incentive Guidelines matrix (secure login required).

Membership Dues/Fees

Federally Sponsored Projects

An individual's membership in business, technical, and professional organizations is generally not an allowable expense as a direct charge on a federally sponsored project and as such will be blocked in Oracle.  Any exceptions are approved on a case-by-case basis.  If the question arises during proposal preparation and budget development, contact your institutional official.  If the question arises after an award has been made, contact your OSR Post Award Research Accountant.

Non-federally Sponsored Projects

An individual's membership fees in business, technical, and professional organizations may be charged to non-federally sponsored projects (excluding sponsors who cite Uniform Guidance) if there is direct benefit to the projects that is adequately articulated in the business purpose of the expense.  For example, a grad student is presenting a paper to disseminate the results of a project at a conference that requires presenters to be members or similar.

Always Unallowable Membership Dues/Fees

Membership fees or dues, such as airline, social, dining and country club dues cannot be charged directly to federal or non-federal sponsored projects. Such expenses must be coded to unallowable membership fees/dues (52255)

Mobile Equipment

Are cell phone charges (including stipends) allowable on sponsored projects?

Mobile equipment expenses are not normally chargeable to federally-funded sponsored projects or to state-funded projects subject to OMB 2 CFR 200 "Uniform Administrative Requirements, Cost Principles and Audit Requirements" Research Policy Handbook Section 15.4. The Office of Sponsored Research must approve exceptions when a proposal is submitted for any sponsored projects, both federal or non-federal 

Reference
Stanford Administrative Guide Chapter 8.1.3

Participant Support Costs (PSC)

Per Uniform Guidance (UG), Participant Support Costs (PSC) are "direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects".  In some instances Stanford students and post docs may be participants. However, a Stanford student or post doc cannot be compensated as both an employee and as a participant on the same project. 

Historically, the National Science Foundation (NSF) has been the primary federal sponsor that awards funds for PSC.  However, we’re seeing more examples of PSC being proposed and awarded by other federal Sponsors such as the NIH, NASA, and ONR.

Federal proposals that seek to request funds for PSC should clearly state so and only request funds for participants as allowed by the given sponsor and program.  The inclusion of PSC activities in proposals should be spoken to in the Statement of Work, listed as line item(s) in the budget, and described in detail in the budget justification that is submitted to the sponsor.

PSC must be explicitly awarded by a federal sponsor in order for the receiving PI/Dept to be able to code PSC qualifying costs as PSC in Stanford’s financial systems.

Key items of which to be mindful when budgeting and charging PSC:

Who qualifies as a participant?

• A participant is defined as a non-employee who is the recipient, not the provider, of a service or training associated with a workshop, conference, seminar, symposium, or other short-term instructional or information sharing activity.  Participants are not interns with paid appointments.  Participants should NOT be performing/providing similar services as other Stanford students (graduate or undergraduate) or Post Docs who are paid as employees, or anyone who has a deliverable or is primarily providing a service to the project. See Stanford's Administrative Guide sections 10.1.1 Undergraduate Student Employment and 10.2 Graduate Student Employment.
• Speakers and Trainers are generally not considered participants and should not be included in this section of the budget. However, if the primary purpose of the individual’s attendance at the conference is learning and receiving training as a participant e.g. a train the trainer type conference, then the costs may be included under participant support.

PSC Budgeting Considerations

• PSC is excluded from a project’s Modified Total Direct Cost (MTDC) base and will not accrue any F&A/IDC as per Uniform Guidance and Stanford’s most recent indirect cost rate agreement.

  • Note, exclusive to NIH R25 programs/awards only, this specific program allows to charge 8% F&A/IDC on an approved PSC budget category.

• Qualifying participant costs e.g., stipends or subsistence allowances, travel allowances, and registration fees should be budgeted under "Section E. Participant/Trainee Support Costs" of federal budgets.  Participants costs should NOT be listed in the project budget under a personnel category.  PSC funds awarded for participants do not have fringe benefits and F&A costs associated. 
  • It is unallowable for budgeted project personnel functioning as non-participants on a project to be re-categorized as participants to “save” on fringe and F&A costs.  
• Costs related to a conference (e.g., venue rental fees, catering costs, supplies, etc.) that will be secured through a service agreement/contract are NOT PSC.  These costs should be budgeted as "Other Direct Costs" to ensure appropriate allocation of indirect costs.
• Participant Support Costs are NOT incentive payments to research subjects. Human subject incentive payments should be included in federal budgets under “Other Direct Costs” to ensure appropriate allocation of indirect costs.
• PSC should NOT be used on a non-federal sponsored research project, unless required by the sponsor (very rare).

Participant Stipend Management

• A participant’s stipend should be a set amount of money to be paid directly to the participant. Conditions for receiving a stipend should be in writing and provided to participants prior to their participating in the program.  Program completion should be attested to by the project PI. Granting agencies may have specific guidelines for participant stipends. Stipend payments should not be paid based upon the number of hours devoted to the project i.e., PSC payments are NOT salaries where individuals only receive payment for work performed.
• Participants are NOT required to provide any deliverable, other than meeting the program requirements (e.g., attendance, testing, etc.).

PTA Setup and Coding of PSC

• For ALL new PTA setups, the PSC ET, 52436, is by default blocked unless the sponsor has explicitly awarded funds in the PSC budget category. If PSC is an approved budget category on a project, the OSR Post Award Accountant will unblock the PSC ET during their portion of the account setup process. PSC must be budgeted into its own specific Task.  PSC qualifying and coded expenses can only be charged to PSC Task of a project.
  • If you have an existing project with sponsor approved PSC funds, but the PSC ET remains blocked on your project’s PTA, you can from within the given project record in SeRA submit a Central Office Request - Update Expenditure Type to request that your OSR Post Award Accountant unblock the PSC ET.  If a separate PSC task has not already been created, one will be created.
• For projects with sponsor approved PSC budgets, use ET 52436 Participant Support Costs Uniform Guidance for PSC qualifying expenses.
  • Note, there are a small number of older pre-Uniform Guidance awards (~12) still able to use the old Participant Support Costs NSF Only ET 52435.
• Stanford's Graduate Financial Services (GFS) system does not accept the PSC ET 52436. Thus, for projects that include PSC and where the participants will be Stanford graduate student and/or post docs, the receiving department as part of PTA setup for a project should indicate this in the comments of the New PTA setup transaction so that their OSR Post Award accountant can unblock the more general stipend ET that GFS will accept to allow the payment of PSC stipends to Stanford grad students and post docs who will be participants through GFS. If a department does NOT indicate that sponsor approved PSC stipend payments will be issued to Stanford grad students and/or post docs at the time of New PTA setup, they can after the initial PTA setup is complete,  from within the given project record in SeRA, submit a Central Office Request - Update Expenditure Type to request that their OSR Post Award Accountant unblock the general stipend ET on the PSC task of the project. 

When to Seek Prior Approval for PSC Rebudgeting

• For projects with sponsor approved PSC budget allocations, sponsor prior approval is required to rebudget any project funds out of the PSC budget category to another category.  Sponsor prior approval is NOT required to rebudget project funds into the existing PSC budget category from another category, assuming there will be no change in the project's scope of work.
• If an award has not been approved by a sponsor for PSC, a PI/Depts should not be charging the PSC ET, and in most cases won’t be able to as a result of Stanford PTA setup limits.  If an existing project without a sponsor approved PSC allocation would like to incur PSC qualifying costs and code them as PSC, sponsor prior approval for the addition of the PSC activity may be required.  The determination of whether sponsor prior approval is required will be largely determined by if this change is represenative of a change in the project’s scope of work and/or if there is a sponsor and/or award level restriction for incurring PSC.

• If a PI/Depts charges PSC coded expenses on awards where they were NOT approved by the sponsor for PSC, the Dept Award Manager(s) will need to re-code those expenditures to the appropriate non-PSC ET(s) and will incur full IDC.

Visa Costs

Uniform Guidance, Section 200.463(d) Recruiting, describes when visa costs are allowable as a direct cost on federal awards:

Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a Federal award. For these costs to be directly charged to a Federal award, they must:
(1) Be critical and necessary for the conduct of the project;
(2) Be allowable under the applicable cost principles.

Basic visa application and required fees, such as anti-fraud fees, are allowable direct costs provided they meet the definition above. 

Premium processing fees, dependent form fees, or Stanford internal processing fees are NOT allowable as direct charges to a federal award.

Note: If the employee resigns within 12 months of recruitment, for reasons within his/her control, the associated relocation costs, including any visa costs, must be removed from the Federal award and coded to the appropriate unallowable expenditure type.

Visa Costs FAQ's

1. I have a postdoc or research associate that is coming from outside the U.S. to work on my federal award, can I charge the cost of their visa to the grant?  
   •  According to the Uniform Guidance [§ 200.463 (d) “Recruiting Costs”] you may charge visa application fees to your grant provided the postdoc/researcher is critical and necessary for the conduct of the project.
2. I have a postdoc or research associate that needs to have his/her visa renewed, can I charge the cost of his visa to the grant?  
   • No. Only initial visa costs are allowable as part of recruitment.
3. I have a postdoc who is here on a J-1 visa and is transitioning to a H-1B visa.  May I charge the costs of the new H-1B visa to a federal award?
   • No.  Only those visa costs associated with the initial recruitment may be directly charged to a federal award.

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