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

Equipment Maintenance Contracts and Extended Warranties

Family & Medical Leave Salary [that is not covered by disability insurance]

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.
• In the School of Medicine, clinician educator (e.g. clinical professor) bonuses, while not blocked, are not allowed to be charged to sponsored projects.

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 benefited 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).

Equipment Maintenance Service Contracts and Extended Warranties

Maintenance service contracts 

Maintenance service contracts are routine servicing of equipment to maintain its intended life and keep it in efficient operating condition.  Maintenance service contracts covering the time a project will be active and using the given equipment are generally an allocable and thus allowable Other Direct Cost on sponsored projects, unless a specific sponsor or award has explicitly disallowed said costs.  When allowed (usually), use ET 53511.

Extended Warranties

Extended warranties are nearly always unallowable as direct costs on sponsored projects and thus should neither be budgeted for nor charged to sponsored projects.  Extended warranties may be charged to most non-sponsored awards/PTAs.

Family & Medical Leave Salary [that is not covered by disability insurance]

Per Uniform Guidance 200.431, salary during authorized periods of leave may be charged to sponsored projects/are allowable provided costs are equitably allocated to all related activities under our institutional policy.

Thus, provided a sponsor does not have a specific prohibition against it, and the PI does not anticipate the sponsored project will be negatively impacted, then salary not otherwise covered by disability benefits may be charged on sponsored projects.  However, if the PI thinks these costs will negatively impact the award, then non-sponsored funds would need to be used to cover those costs not paid by disability benefits.

Note, a sponsored award cannot support a higher proportion of the leave salary than the award was supporting immediately prior to the leave.

• For example, if a sponsored project ends during the leave period, the % salary that was being charged to that sponsored project must then be charged to a non-sponsored PTA.  It cannot be charged to another sponsored project.

If a sponsored project starts after the leave period begins, then that project may not be charged until the individual returns from leave and begins to work on that project.

Agency Specific Information and Resources

NIH

The NIH has a "Family Friendly" policy that addresses the use of grant funds to cover the salary not covered by disability insurance (aka "supplemental" funds). This policy allows grant funds to be used for this purpose provided it follows our institutional policy. Note: if the leave will be greater than 3 months, prior approval may be required.

NIH has a specific policy just for NRSA trainees. For NRSA trainees and fellows, stipend support may be provided for up to 8 weeks.

NIH Resources

• NIH FAMILY FRIENDLY INITIATIVE
• FAMILY FRIENDLY FAQS
• NIH Family Friendly Policies Podcast
• NIH GPS CDA leave policies
• NRSA POLICIES

NSF Resources

• NSF - Career-Life Balance

Stanford Resources

Faculty and Staff

• Administrative Guide
• Faculty Handbook

Postdoctoral Scholars

• Research Policy Handbook
• Postdoc Benefits - Paid Salary
• Postdoc Benefits - Stipend Paid Postdocs
• Office of Postdoctoral Affairs - Information Presentation

Graduate Students

• Graduate Student Maternity Leave Funding

Still have questions?  For sponsored projects within the School of Medicine, please contact your department’s Research Financial Compliance Manager.  For sponsored projects in all other schools, please contact the Client Advocacy & Education Team.  We’re here to help!

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)

The Uniform Guidance defines a Participant as "generally means an individual participating in or attending program activities under a Federal award, such as trainings or conferences, but who is not responsible for implementation of the Federal award. Individuals committing effort to the development or delivery of program activities under a Federal award (such as consultants, project personnel, or staff members of a recipient or subrecipient) are not participants. Examples of participants may include community members participating in a community outreach program, members of the public whose perspectives or input are sought as part of a program, students, or conference attendees."

Moreover, the Uniform Guidance defines Participant Support Costs (PSC) as "means direct costs that support participants (see [above] definition for Participant in § 200.1) and their involvement in a Federal award, such as stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care, and per diem paid directly to or on behalf of participants."

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 an individual participating in or attending program activities under a Federal award, such as trainings or conferences, but who is not responsible for implementation of the Federal award.   Individuals committing effort to the development or delivery of program activities under a Federal award (such as consultants, project personnel, or staff members of a recipient or subrecipient) are not participants.  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.) 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

• 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.

Paying PSC

Stanford Participants

• 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 to prompt their OSR Post Award accountant to 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. 

Non-Stanford Participants

• Non-Stanford participants can be reimbursed through visitor expenses requests (ER) for actual travel expenses.  The PSC ET is available within the ER system.  Reference: Fingate: Paying Visitors.  
• Alternatively, departments can request for non-Stanford participants subsistence payments to visitors.  Reference: Fingate: Request Subsistence Payments for Visitors.  Please note, when you request a payment to a non-SU person it will by default be processed against ET 56005.  However, you can request that Payroll use the PSC ET 52436 by indicating this on the SU-21 on the form.  

Unallowable PSC Expenses

• Speakers and Trainers are generally not considered participants and thus their expenses should not be charged as PSC.  These costs should be charged to the non-PSC task on the project using the appropriate non-PSC ET(s) to ensure appropriate allocation of indirect costs.
• Costs related to a conference (e.g., venue rental fees, catering costs, supplies, etc.) are NOT PSC.  These costs should be charged to the non-PSC task on the project using the appropriate non-PSC ET(s) to ensure appropriate allocation of indirect costs.

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 representative 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.

Not finding for what you're looking?  Have other "Can I Charge That?" questions?  Contact the Client Advocacy & Education Team.  We’re here to help!