Justification Nation Part 8: Other Direct Costs – A Few Items Like Tuition Remission, Animal Care Costs, Human Subjects Costs, and Consultants

Other Direct Costs

It sounds like a category for a few leftover items, things that are not as important, but that’s far from the case. Tuition remission costs, animals and animal care, human research participant costs (as well as patient care costs), shipping research samples and equipment, and consultant payments are some of the main budget items that are included in this section of the budget and budget justification.

Laboratory mouseTuition Remission

According to OMB Circular A-21, tuition remission for students is an allowable direct charge on federal grants and contracts provided that the following conditions are met:

  • There is an employee-employer relationship between the student and the institution for the work performed;
  • The tuition remission is a reasonable compensation for the work performed and is conditioned explicitly upon the performance of necessary work; and
  • It is the institution’s practice to similarly compensate students in non-sponsored as well as sponsored activities.

For the NIH, the graduate student compensation limit is the NRSA zero-level post-doctorate stipend level when budgeting tuition. Check your institution’s policies when justifying your school’s stipend and tuition level’s if they are higher than this rate. The NIH guidelines ask you to include your school’s tuition rates.

Animals and Animal Care

Providing details about the animals and animal care costs (mapped out against the research plan) helps the reviewers to see how well the investigator has planned and estimated the costs of his or her research. Include costs of any animals that need to be purchased, and the per diem rates for the animal care facility. If the research plan has any unusual features (unusual procedures, follow up time, etc) its best to explain in this section if there are costs involved that are related to the research plan.

Human Participant Reimbursements/Research Patient Care CostsMedical Student

Few research studies accrue patients right out of the gate, and have steady accrual rates. In addition, complicated protocols with multiple visits and payments for participation require an elegant justification which clearly outlines the payments to research participants on the timeline that reflects the participation of subjects mapped out against the research plan.

Understanding this – having the PI explain it to you and refine it with you is key. I’ve seen some payment tables for research subjects that remind me of what it must be like to direct the air traffic control center at O’Hare airport, they are that complicated. But that’s what it takes to justify thousands of dollars in participant  payments.

BY THE WAY…Don’t even think about calling these payments an honorarium or an incentive. The institutional review board, the local review board that reviews the study and ensures that we are protecting human subjects, does not want to see that we are considering these payments an incentive for participation. The dollar amount of these payments should not be coercive (it should reflect the real, reasonable cost of what it means to participate in the study – to truly be a reimbursement of their time) and should not act as an incentive for them to participate.

If you are budgeting research patient care expenses for a clinical research study, you should include the following information in your budget and budget justification:

  • The names of any hospitals and/or clinics and the amounts requested for each.
  • Provide detail for inpatient and outpatient costs separately.
  • Provide cost breakdown, number of days, number of patients, costs of tests/treatments.
  • Justify the costs associated with standard care or research care.

Consultants

Consultants are individuals or small companies providing a specialized service to meet an aim of the sponsored project. The consultant usually charges a rate by the hour or by the day, and does not use any resources of the University in order to deliver services to the project. The consultant does not exercise any discretion over the project’s direction or aims, and once the consultant delivers his/her services the consultant’s work is complete.

To budget and justify a consultant on a sponsored project, your institution may have a standard form (the consultant is held to the financial conflict of interest regulation that NIH and NSF have recently established) but the federal flow through terms do not apply to a consultant agreement, who is treated like a vendor.

To budget a consultant on an award, draft or obtain a letter from the consultant that states the following information: (Check out my previous post on subcontractors and consultants on budget justifications)

  • Intent/availability to work on the project (dates) and support of the project.
  • Hourly/daily rate of pay
  • Time frame for completed work
  • Statement of work they will perform
  • Travel needed to perform work

Include the basic information on the budget justification and attach the letter to the application. Careful attention to the Other Costs section can ensure that these costs are fully accounted for and funded when the budget and justification is reviewed by the agency.

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