I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder regarding the use of funds from sponsored projects for stipend costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research 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 research. Procedural statements support the CU Boulder Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
CU Boulder 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.
A. Federal Awards
At CU Boulder, 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 CU Boulder, 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 their Personnel Effort Reporting (ePER) form.
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 projects. Some sponsors may restrict additional compensation for students receiving stipends. Please refer to your sponsor guidelines or contact your SPA Grant Accountant if you have questions
B. Non-Federal Awards
The basic criteria for stipends costs are similar for non-Federal sponsored projects, 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.
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.
CU Boulder uses the following job codes to pay stipends:
Job Code 3204 – Pre Doc Trainee (Fellowship): Graduate students on training grants or fellowships – no service to the university is expected. Payment allows for students to continue their education (definition from the Graduate School Appointment Manual). Stipend payments for job code 3204 are posted on the financial statements in account code 495201 – Pre Doc Fellow Stipends HRMS.
Job Code 3205 – Student Stipend (Non-grad): Trainees, who are not graduate students but enrolled in high school or undergraduate programs, on training grants – no service is expected. Payment allows for the students to continue their education (definition from the Graduate School Appointment Manual). Stipend payments for job code 3205 are posted on the financial statements in account code 495202 – Student Fellowship Stipends HRMS.
Job Code 1438 – Post-Doctoral Fellow: The Post-Doctoral appointment is restricted to postdoctoral scholars who receive fellowship awards directly from a funding agency and have a direct reporting relationship to the funding agency – that is, postdocs who have applied for and been granted their own fellowship funding (definition from the Postdoctoral Handbook). Stipend payments for job code 1438 are posted on the financial statements in account code 400840 – Postdoc Fellowship Stipends.
When an individual is paid a stipend through one of the job codes above, he/she holds an appointment with CU Boulder in the HCM system in order to administer the stipend payment. He/she is not considered a CU Boulder employee. There are circumstances when a stipend payment is necessary, but the individual does not hold an appointment in HCM. An example would be an NSF participant support project that is hosting a workshop in the summer for local high school teachers, and the grant allows for stipend payments to the teachers. In these cases departments will use a payment authorization form and charge the stipend to account code 495302 – Participant Stipends Non-HRMS. Please visit the Procurement Service Center website for more information about using a payment authorization form.
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 OCG Grant or Contract Officer 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 project, will be retained in Boulder eRA (BeRA) for future reference should the expenditure be questioned at a later date.
D. Related Procedural Statements, Forms, Policies, and Tools
NIH training grants and fellowships allow stipends. The NIH Grants Policy Statement states, “Stipends are not allowable under research grants even when they appear to benefit the research project”. Therefore stipends are not allowed on NIH research awards.
Departments should use the payment authorization form to pay the undergraduate students their stipend for attending the conference.
When a student has work expectations and service to the university is rendered, this is an employee/employer relationship, the pay is considered compensation, and the student should not be paid a stipend. The undergraduate student should be paid with the Student Assistant Job Code Series (4101 – 4106), depending on the level of the position. Payments for these job codes are posted on the financial statements in account code 407600 – Student Hourly Pay.
Here are two potential options to provide additional funding for students.
1. The trainee may be able to receive stipend supplementation if provided from non-sponsored project funds. No service to the university for the stipend supplementation is required.
2. Wages over and above the stipend could only be charged to a sponsored project if there is work effort on a sponsored project separate from the one funding the stipend. This is not allowed by all sponsors. Check sponsor requirements or contact your SPA Grant Accountant for more information. If additional effort would cause the student to exceed standard graduate student full-time status, approval from the Graduate School will be needed.