SUBJECT: Teaching Cost on Research Agreements
SUPERSEDES: GIM 32 (November 15, 1983)
RELATED INFORMATION: GIM 24
This memorandum is intended to clarify federal regulations regarding the charging of teaching costs to research agreements.
In general, teaching costs are not allowable charges to research grants or contracts from a federal agency but may be allowable on training grants, capitation grants, and certain other special awards that clearly indicate allowability of such costs in the award document or policy guidelines. Supervision of students and employees whose work is solely related to the purposes of the grant is fully allowable.
Educational supervision of independent study (where the effort contributes to the research project but is for the education of the student) is an allowable cost to research agreements (grants/contracts) subject to the following limitations.
Educational supervision of independent study students working on projects supported by federal research awards other than National Science Foundation (NSF) and not exceeding 5% of individual faculty member's activity per quarter:
Educational supervision of students working under research agreements specified above and who are financially supported from any source through the University payroll may be charged to the agreement if total activity so charged is 5% or less. Faculty should indicate on that quarter's Faculty Activity Analysis (FAA) form that the students are supported. Documentation indicating names and pay status of students being supervised in the independent study should be maintained in the department for occasional review by internal audit.
Supervision of independent study students working under research agreements specified above but not supported from any source may be charged 50% to the grant and 50% to nonfederal funds. For reporting purposes, the course information must be listed twice on the FAA form with the appropriate source of funds indicated for each listing.
Educational supervision of independent study students working on federal research projects other than NSF and exceeding 5% of individual faculty member's activity per quarter:
No faculty effort in excess of 5% may be charged as supervision of independent study students working under research agreements specified above without either written approval of the funding agency or adequate documentation maintained in the department justifying the increased amount of supervision. Adequate documentation should include names of students supervised, information showing financial support for students, course registration verification, and publications citing the student(s) as contributing authors, written results of experiments done by the students, or any other evidence which demonstrates that the project supported by the agreement benefited from the student's work.
If students are not supported, only 50% of supervisory activity may be charged to the agreement. The other 50% must be paid from nonfederal sources. Complete documentation as noted above is required.
Educational supervision of independent study students working on NSF research projects and not exceeding 10% of individual faculty member's activity per quarter:
Educational supervision of students working under an NSF research agreement may be charged to the agreement if total activity so charged is 10% or less. No distinction is made between students who are paid to work on the project and those who are not. This authority is in addition to the 5% limitation for all other federal agencies.
Educational supervision of independent study students working on NSF research projects and exceeding 10% of individual faculty member's activity per quarter:
No faculty effort in excess of 10% may be charged as supervision of independent study students working under an NSF research agreement without review and approval by Office of Sponsored Programs under the Organizational Prior Approval System (OPAS).
Supervision of independent study activity must be directly related to the project supported by the agreement to be charged to sponsored project budgets.
Guest lecturing charged to federal research projects:
Up to four guest lectures per quarter may be charged to federally sponsored research projects under activity code 501 on the FAA form. This activity should not be reported under the "scheduled courses" section of the form.
Attachment A contains an excerpt from Government Publication (Circular A-21) describing what is allowable. Circular A-21, issued by the Office of Management and Budget is a directive to all Federal agencies regarding cost principles applicable to most Federal research agreements. This document clearly indicates that charges should not be made to research agreements for lecturing or preparing for formal courses listed in the catalog (excluding independent studies courses which are subject to the limitations about). Care should be taken when submitting faculty appointment papers to be sure the activities covered by a particular grant or contract are consistent with Federal limitations.
In addition, at the time the FAA forms are being certified, a review should be made to confirm that the completed form accurately depicts the effort expended on the various activities and that the direct cost activity is an allowable charge to the source of funding. Any questionable items should be discussed with the departmental chairperson.
Inquiries regarding allowability of costs and the proper documentation of costs may be referred to the Grant and Contract Accounting Office, Ext. 5-1271.