The post-doctoral trainee on our T32 award was paid the correct amount of stipend but was paid out of object code 01-20, not 01-50. Is this allowable?

No. Per NIH and UW policy, trainees must be paid the correct stipend amount and the stipend must be paid from the correct object code. Object code 01-20 is reserved for Auxiliary Teaching Staff Salaries only; payment under this object code indicates an employer-employee relationship, which is not allowable on T32 awards. If a trainee is not paid under the correct object code (01-50 for post-docs; 01-90 for pre-docs), the trainee will receive fringe benefits that are unallowable under NIH policy.

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We overpaid a trainee on stipend and fringe. Rather than making the trainee pay us back, is it allowable to transfer excessive stipends or fringe benefits from the T32 grant to a department budget?

No. While transferring excessive stipends or fringe benefits to a department budget will result in charging NIH the appropriate amount of costs, the trainee is still receiving additional stipends and fringe benefits. Additional benefits paid to a trainee may indicate an employer-employee relationship, which is not allowed under NIH policy. Also, trainees must be treated consistently across the University, regardless of the financial condition of the department.

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The HRP Modernization (HRPM) fee is charged annually. What is the best practice for allocating this fee to applicable unit budgets?

The HRPM fee is allocated to units based on FTE, so units should also use effort to reallocate this cost to budgets where the HRPM fee is an allowable expense. This reallocation should be done via a Cost or Expense transfer using the HRPM fee designated Object Code 03-05.

The HRPM fee should be allocated on a regular basis over the course of the year. This will ensure that budgets are being allocated on the basis of actual effort and not just the effort allocation at the time the HRPM Fee is being charged to the unit. 

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An Award has a Total Period End date in October 2016. A conference related to the continuation Award will be held in January 2017, but the registration fee is due by October 2016. Can the conference fee be charged to the Award that ends in October 2016?

No, the conference registration fee is unallowable on the Award that ends October 2016. The conference occurs after the end date of the Award and would not directly benefit the Award. If the continuation Award allows for pre-Award expenditures, the fee could be paid in October and charged to the continuation Award. In the absence of a continuation Award, the department may request an No-Cost Extension.

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Post Award Fiscal Compliance email: gcafco@uw.edu

For questions and issues relating to Effort Reporting, email: effortreporting@uw.edu

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