GAP 200.310, Compensation of Graduate Students on Sponsored Research Projects

Contents

1. General
2. Requirements
3. Procedure
4. Federal Regulations

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 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, as described by GAP 200.170, Effort Reporting.

Note:  this General Accounting Procedure does not describe stipends provided by sponsors for items other than services provided on a research project.

II. Governmental Requirements

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance (UG), in 200.466, Scholarships and student aid costs, establishes the allowability of providing tuition remission and other forms of compensation paid as, or in lieu of, wages to students. 

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

1. Tuition (remission) is allowable for PhD Students if it is in lieu of wages for necessary work. However, there must be:
   • Reasonable compensation for necessary work, and
   • Consistent application throughout the institution. 
   • The student must be enrolled in an advanced degree academic program, with activities of the award relating to the degree program.
2. Tuition Remission may be charged on an average rate basis.

III. Procedure

Duke University compensates PhD 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 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 (F&A Costs) calculation (for information regarding F&A Costs, see GAP 200.330, Facilities and Administrative Costs),
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 either the Office of Research Administration (ORA) or the Office of Research Support (ORS) 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.

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 student effort. However, the Department can cost-share the Tuition Remission amount by processing a Journal Voucher crediting the Tuition Remission amount to the sponsored project and debiting the Tuition Remission amount to another funding source. G/L 808300 Cost Sharing: Tuition Remission must be used on both sides of the JV entry. This process must adhere to the procedure set forth in GAP 200.140, Cost Sharing on Sponsored Projects.

If the Sponsor does NOT allow Tuition Remission, the Tuition Remission amount must be assessed, but will be charged to another non-sponsored funding source; this process is managed by the Graduate School and the Office of Post Award Administration. Unallowable Tuition Remission should not be cost shared by the Department.

IV. Federal Regulations

This GAP reflects the provisions of the UG.  The UG became effective as of December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions.  It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor's policies and/or procedures.

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. Failure 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.