GAP 200.310, Compensation of Graduate Students on Sponsored Research Projects

  1. General
  2. Requirements
  3. Procedure
  4. Assistance

 


 

I. GENERAL

Compensation of Graduate Students, for services provided on a research project is allowable under specific requirements. Duke University compensates Graduate Students a salary/living wage for performing necessary work on Sponsored Research Projects through the corporate Payroll System and, specifically for PhD Graduate Students, via tuition remission assessed on an average rate basis. The salary/living wage payments are recorded as income; the tuition remission is not. While both payments are considered compensation from a sponsor perspective, tuition remission is automatically assessed on an average rate basis of salary (similar to fringe benefits), so that only salary must be certified as part of the Effort Reporting System.

Guidance provided herein is effective Fall 2015 tuition; September 1, 2015.

 

II. GOVERNMENTAL REQUIREMENTS

The Office of Management and Budget publishes regulations covering the administration of Federal Awards. Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133. Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance). Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency. While the award date will determine which set of guidelines should be followed, the requirements for handling of tuition remission are unchanged.

The principle criteria for the charging of tuition on a research grant or contract are as follows:

  1. Tuition (remission) is allowable for PhD Graduate Students if it is in lieu of wages for necessary work. However, there must be:
    1. Reasonable compensation for necessary work, and
    2. Consistent application throughout the institution.
  2. Tuition Remission may be charged on an average rate basis.

 

III. PROCEDURE

Duke University compensates PhD Graduate Students performing necessary work on research projects in two methods. A salary/living wage is set by the department (typically based on Graduate School recommended rates), paid via the Payroll System and directly charged to the grant. Tuition Remission is directly charged to the grant on an average rate basis, with the average rate being set annually by the Graduate School and approved by Financial Services.

The following steps ensure compliance with Federal Cost Principles requirements:

  1. Record the proposed salary/living wage in the salary section of a proposed budget (classified as compensation),
  2. Record the Tuition Remission under the non-salary, other or tuition category, calculated as the annual average rate basis of PhD graduate student salary,
  3. The salary/living wage is included in the calculation of indirect costs, as with all other salaries,
  4. Tuition Remission is EXCLUDED from the Facilities and Administrative Costs calculation,
  5. The salary/living wage is reported in the Effort Reporting System. Tuition remission is directly tied to salary through the average rate basis; therefore it does not need to be certified separately.

The method used to charge research assistants’ compensation on research grants must be consistent across the university per federal regulations.

Salary/living wage amounts for graduate assistants may vary from school to school and department to department, however, it is advisable the amounts are consistent within a school or department to ensure parity individual graduate students. An upper limit for graduate student compensation may be benchmarked in relation to the NIH limitation on graduate assistant salaries. Graduate Students salary may be budgeted for up to NIH Postdoctoral Level 0 in an original proposal, and may be rebudgeted to NIH Postdoctoral Level 1 after an award has been made. Contact your Pre-Award Office for the current limitation level or consult the NIH Guide. The NIH limitation includes salary/living wage, tuition remission, and fringe benefits

The following General Ledger (G/L) Accounts should be used to record the compensation of Graduate Students working on Sponsored Research Projects.

601200 Research Assistant: Ph.D. Students
Represents salary paid to exempt graduate students who are working as Research Assistants. Can be used for base salary in Job Code 1590 or supplemental pay for incremental RA work in Job codes 1590, 1502, and 1594. This account can only be used for registered Duke students. Tuition Remission will be assessed.
600800 Cost Sharing: Research-Graduate Student
This G/L account should be used to record cost sharing for a graduate student that would otherwise have been paid from G/L 601200. Tuition Remission will be assessed.
634700 Tuition Remission
Will only be used when salary is paid using G/L accounts 601200 or 600800.

Duke university’s process of semester and year-end reconciliation will ensure accurate reconciliation and assessment of tuition remission on research projects. Deviations beyond accepted norms will be identified and researched, thereby strengthening internal controls to maximize compliance.

Cost-Sharing Tuition Remission
If the Sponsor allows for Tuition Remission but does not provide sufficient funds, the Tuition Remission will nevertheless be charged to the sponsored project proportional with PhD graduate student effort. However, the Department can cost-share the Tuition Remission by processing a Journal Voucher crediting the Tuition Remission to the sponsored project and debiting the Tuition Remission to another funding source. G/L 808300 Cost Sharing: Tuition Remission must be used on both sides of the JV entry.

If the Sponsor does NOT allow Tuition Remission, the Tuition Remission must nevertheless be assessed, but charged to another non-sponsored funding source (e.g., Departmental fund). Unallowable Tuition Remission should not be cost-shared.

 

IV. ASSISTANCE

Please contact the following offices for assistance or to answer questions regarding this procedure:

  • The Graduate School
  • Office of Research Administration (Medical Center)
  • Office of Research Support (Campus)
  • Office of Sponsored Programs

919-681-1555
919 684-5175
919 684-3030
919 684-5442

 

Note: This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc. Unless otherwise noted, this GAP applies to all sponsored projects. This guidance is administrative in nature and is not a cost reimbursement policy. Faliure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.