Charging Stipends on University of Arkansas Sponsored Programs
Introduction
This document is intended to serve as formal guidance for University of Arkansas regarding the use of funds from sponsored programs for stipend costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance ( 2 CFR §200.403-405 ); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored program. Procedural statements support the University of Arkansas Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
Definitions
University of Arkansas considers the definition of stipends to be:
Stipends are payments made to individuals for subsistence support or to defray expenses during an academic appointment or research training. No service to the university is expected in return for the support.
The term “stipend” is often used to refer to compensation. It is important to understand the purpose of the payment in order to determine whether or not it is compensation for services rendered. Even if a sponsor refers to a payment as a stipend, if services to the award are expected, it should be paid as wages.
Application
Federal Awards
At University of Arkansas, stipend payments are not considered compensation for services rendered, but subsistence support allowing for a student to continue his/her education. When a student is paid a stipend from University of Arkansas, there is no service to the university expected, nor does it create an employee/employer relationship. Additionally, when a student is paid a stipend, this is not included as effort on effort certification approval process.
Therefore, since stipend payments are not compensation for services rendered, they are not allowable on federal awards unless the purpose of the award is to provide training to selected participants, participant support, or fellowships, and the charge is approved by the sponsoring agency. Examples of federal awards where stipend payments are allowable include NIH training grants, NASA and NIH fellowships, and NSF participant support programs. Some sponsors may restrict additional compensation for students receiving stipends. Please refer to your sponsor guidelines or contact your Research Accountant if you have questions
Non-Federal Awards
The basic criteria for stipends costs are similar for non-Federal sponsored programs, but it is important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the sponsor, even when the non-Federal sponsor may follow more flexible spending guidelines, it should be clear that the stipend payment is for subsistence support or to defray expenses and not for services rendered to the university.
Process
At Proposal
Sponsored funds intended to support training or research training will state that intention clearly in the agency program announcement. When submitting a proposal for an award that allows stipends, the stipend costs should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the stipend costs. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
Fellowship Form
University of Arkansas uses the Fellowship/Stipend/Tuition Award Notice to pay stipends to award recipients. The Notice form contains pertinent information pertaining to the student’s eligibility for a stipend. The academic department staff initiates the notice. The key information that needs to be entered is the student name and ID, the semester, the type of distribution for the student (tuition, fees, room & board or stipends), and the cost center to be charged. Upon completion, the form must be approved by the Principal Investigator and department head before processing.
Research Accounting will obtain the awards that are paid from sponsored program funds, will perform a reasonableness check and will forward form to either Financial Aid (degree seeking students) or Treasurer’s Office (non-degree seeking students). Once a week, an accountant in Research Accounting is responsible for querying UAConnect stipend payments and posting the stipend payment to the sponsored program.
Sponsorship Acknowledgement Form
Associated with the sponsorship form is an acknowledgement form used to inform the award recipient that the award is truly an award and not work-for-hire, and to inform the recipient of the possibility that acceptance of the award could affect other student financial aid they may have been awarded. This form has to be filled out by the student as a requirement to receive the award. The form must be retained by the academic department for recordkeeping purposes.
After an Award is Funded
Not every cost can be anticipated at the time of proposal preparation. In the event that an unbudgeted stipend cost is required after an award is funded, the department should work directly with their RSSP Grant Specialist to determine if sponsor approval is required. Any stipends on federal awards require sponsor approval, except those already noted. The written sponsor approval, as well as the justification explaining the purpose and need for stipend payments on the specific program, will be retained in Razorgrant for future reference should the expenditure be questioned at a later date.