Impossible Conversations: What can and cannot be charged to a grant, when and why

It’s a rare investigator who thinks like NIH.

As research administrators, we understand the guidelines and rules that govern what can be charged to awards. We understand how strict sponsors are regarding allowable costs (all together now, what are the four criteria from A-21, say it with me?).  We track these issues carefully to allow our investigators to develop their research careers and the university we serve to continue to pursue scientific discovery in a compliant manner.

And then we meet with our investigators, who look at us quizzically when we say we can’t charge boxed lunches for an educational seminar to a grant. Or we can’t provide lunch as a matter of course to residents on a training grant in a urban medical clinic. Or we can’t put 100% of the cost of a toner cartridge on a grant, because we can’t confidently allocate the cost of the toner 100% of the time to the grant.

And the PI looks at us like have taken leave of our senses.

My personal favorite is the conversation that takes place 90 days before the end of the budget period – or 90 days before the end of the grant – period. If the $100,000 piece of equipment was allocable or allowable before – why not in the last three months of the budget period or the grant? Ah yes.

If we’ve done our jobs well – and we do – as best we can – we’ve got a good budget and justification to work with. We can talk through the guidelines of the award, and the budget, with the investigator, and project out the spending on the award against the project milestones to keep everything on track.

But when our PI wants to do something new, or the plan changes, we’ll be prepared to discuss this with him or her having laid the groundwork for the research financial plan for the award in advance.

However, it’s the seemingly inconsistent conversations that can become complicated, especially when a PI feels that the rules are designed to make it more difficult for him or her to progress with the pace of research. Not normally so, but pathologically so. The kind of rules that seem, on their face, to defy all logic and reason, but have some merit when considered carefully.

How can we overcome these odds, when the deck is so stacked against us?

1. Find the low hanging fruit and score a win. Delivering early wins builds your credibility with cranky investigators and allows you to negotiate with them when you have to ask them to “wait” while you find an appropriate solution for an issue that they’d like you to work on that is more complicated and needs a work around. You can buy patience when you’ve delivered wins for them on other issues.

2. Under promise and over deliver. Maximize your chances of success and manage expectations by outlining deadlines and outcomes that are uber-realistic. When you come through with more, it’s a bonus.

3. Go to mat whenever possible.  It’s more work – and half the time, you’ll get turned down. But the effort and time you spend doing it is worth it, because your PI will see that you’re fighting for what they need. That’s integrity. Don’t assume you know the answer. Do the legwork. Deliver.

4. Scrub NO from your vocabulary. There are one thousand ways to redirect behavior that is less than optimal without using the word NO. Try something like “I understand exactly what you’re trying to accomplish, but we’re going to need to use a different strategy to get there…”

5. Find a way to explain that makes sense. At the end of the day, what’s “allowable, allocable, reasonable and consistently treated” makes sense to us, but it’s got to make sense in the world of academics. What tends to be more relevant is a discussion of how charges directly benefit the award itself, and how the charges relate to the scientific aims of the award.

These conversations happen every day, and sometimes it seems like they happen more often than that. As research administrators, we need to remain patient and open to explaining how to allocate funds properly – because these conversations allow us to pick up on how our investigators are thinking about managing their accounts and using their funds. We want to maintain open and honest relationships at all times to know how the funds are being used and to provide the best guidance possible to ensure proper stewardship of sponsored research funds.

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