GAP NO. 200.310
Compensation of Graduate Students on Sponsored Research Projects

I.	General
II.	Requirements
III.	Procedure
IV.	Assistance
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I. GENERAL

Compensation of Graduate Students, for services provided on a research Grant or Contract is allowable, with very specific requirements. Duke University compensates Graduate Students a salary/living wage for performing necessary work on Sponsored Research Projects through our corporate Payroll System and with tuition remission through our Student Information Services and Systems Office (SISS). The salary/living wage payments are recorded as income; the tuition remission is not, but both  payments are part of the Effort Reporting System.

 

II. GOVERNMENTAL REQUIREMENTS

The Office of Management and Budget publishes regulations covering the administration of Federal Awards. The Cost Principles covering Colleges and Universitiesare contained in 2 CFR Part 220 (formerly OMB Circular A-21).

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

1. Tuition (remission) is allowable 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. All compensation, including Tuition Remission, must be included in Effort Reporting {per Section J.10 (Compensation for personal services.) of  2 CFR Part 220 attachment A}

 

III. PROCEDURE

Duke University compensates Graduate Students performing necessary work on research projects in two parts. The salary/living wage is set by the department and paid via the Payroll System and directly charged to the grant. The Tuition Remission is also directly charged to the grant via SISS..

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,
   
   
3. The total salary/living wage is included in the calculation of indirect costs, as with all other salaries,
   
   
4. Tuition Remission is EXCLUDED from the calculation of Facilities and Administrative Costs (F&A),
   
   
5. The total salary/living wage and tuition remission is reported in the Effort Reporting System.

A final aspect of the federal regulations that we must be cognizant of is the requirement for consistency; the method we use to charge research assistants’ compensation on research grants must be consistent across the university.

While salary/living wage amounts for graduate assistants vary from school to school and department to department, it is advisable to keep the amounts consistent within a school or department so that there is not a great disparity among the salary/living wage of individual graduate students. In any case, an upper limit for graduate student compensation might be viewed in relation to the NIH limitation on graduate assistant salaries. You may contact your Pre-Award Office for the current amount of this limitation or consult the NIH Guide.  The NIH limitation includes salary/living wage, tuition remission, and fringe benefits. The Tuition Remission Salary Worksheet provides assistance in this process.

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

601200 Research - Graduate Students
Represents salary paid to exempt graduate students who are directly involved in departmental or sponsored research. This account can only be used for registered Duke students and will be assessed Tuition Remission.

601400 Instruction/Other: Graduate Students (Salary / Living Wage)
Represents salary paid to exempt graduate students who are directly involved in instruction or other activity related o instruction. This account can only be used for registered Duke students.

Tuition Remission
Tuition remission is a form of compensation provided to eligible graduate/professional students performing necessary services on a research project. Tuition remission is paid in lieu of wages, is not subject to Facilities and Administrative Costs (F&A) and is included in the Effort Report for the graduate/professional student.

Recipient Designated
633100 Tuition Remission
633700  Federal Awards – Tuition Remission

Recipient Undesignated
634100 Tuition Remission
634700  Federal Awards – Tuition Remission

 

IV. ASSISTANCE

For assistance in implementing this procedure or if you have questions you may contact one of the following:

Office of Research Administration (Medical Center) Office of Research Support (Campus) Office of Sponsored Programs

684-5175 684-3030 684-5442

 

Note: 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.

GAP History
Issued:	March 2002
Revised:	February 2003
Revised:	September 2005
Revised:	April 2007
Revised:	July 2009
Revised:	October 2009