Definitions

Tuition is the charge or fee for instruction, as at a private school or a college or university.

Tuition is also referred to as “Operating Fee” and is referred to as such in UW policies and some sponsor regulations.  Information on UW’s tuition can be found here.

Tuition is different from a Scholarship which is an amount of money that is given by any person or entity to help pay for a student's education. Scholarships can typically be used to pay for any type of cost, not necessarily tuition.  The scholarship funds can be given directly to the student or to the educational institution.

UW and Federal Policies

As always, the terms of the individual Award, and then the federal sponsor regulations should be reviewed to determine if there are any award- or agency- specific regulations or guidelines regarding the payment of tuition.  If both the award and the federal agency are silent on tuition, then the federal regulations (Uniform Guidance) should be followed. The Uniform Guidance (2 CFR 200) provides regulations for tuition under two sections:

          200.431(j) Fringe Benefits
          200.466 Scholarships & Student Aid Costs

There are two instances when tuition is allowed on a federal award:

  1. The purpose of the federal award is to provide training to selected participants (e.g., Training Grant or Fellowships) and the sponsor allows tuition charges on the award (2 CFR 200.466); and
  2. Paid as a fringe benefit for a graduate student holding a Graduate Student Appointment as defined by the recipient institution. (2 CFR 200.431(j))

Under § 200.431(j), fringe benefits in the form of tuition are allowable so long as the fringe benefits are:

  1. In compliance with the recipient institutions (UW) policies; and
  2. Applied equitably to all students regardless of the funding source.

UW policy, found in Executive Order (EO) 28, states that only those graduate students who have a Graduate Student Appointment (GSA) are eligible to have their tuition covered, either via a waiver or via sponsored funding.

A waiver is when tuition is covered by UW, not sponsor, resources.

Executive Order 28 lists other requirements for a GSA. Tuition is not allowed on a federal sponsored award unless the student has met the requirements of Executive Order 28, or the purpose of the award is to train selected participants.

Note that a GSA is considered full-time effort with 50% time engaged in compensated work.  The balance of time is expected to be expended on his/her studies.  A GSA will have their compensation charged to Object Code 01-40 Graduate School Student Appointments.

Tuition Paid In Lieu of Wages

Under § 200.466, institutions may pay tuition in lieu of wages if certain requirements are met, including that the payments are reasonable and meet the reporting and documentation requirements under § 200.430 Compensation.

The UW complies with § 200.430 Compensation through the Faculty Effort Certification (“FEC”) and Grant & Contract Certification Report (“GCCR”) processes. Tuition (object code 08-05) does not appear on the GCCRs because there is no effort associated with the payment. Since there is no effort associated with tuition in the UW’s financial system, the compensation cannot meet the documentation requirements of § 200.430 Compensation. It is for this reason that tuition paid in lieu of wages (or “stand-alone” tuition) is not allowable on a sponsored award.

Tuition Fees

Only those parts of the tuition and fees that are covered under a UW GSA waiver are allowable expenses on a federally sponsored Award.  For example, if the Activities Fee portion of tuition and fees is not covered under a UW GSA waiver then that fee is not an allowable expense on a federally sponsored award. 

Review Executive Order 28, 3, C, 2 to obtain the current list of allowable fees under a GSA waiver.

Partial Graduate Student Appointments

A GSA is eligible for a tuition waiver if the appointment is for 50% FTE or more for five out of six pay periods and who maintains registration at 10 credits.  

If the GSA has multiple funding sources, the cost of tuition must be allocated to those funding sources in proportion to the effort expended.  For example, if a GSA’s effort was allocated 40/60 on two awards, then the tuition cost would also be allocated 40/60 on those same two awards

As the purpose of a GSA is to work on the federally sponsored award, their compensation must be commensurate with their effort directed towards that award.  So if only half of their salary is paid from the award then only half of their tuition would be allocable to the award.  If their full salary is paid from the award then their full tuition allowance would normally be expected to be paid from the award. 

Non-Federal Award Policies

If tuition is provided under a non-federal award, the award and the individual sponsor’s policies and procedures should be followed.