Other Direct Costs

Consultants differ from Consortiums/Subawards in that Consultants provide advice, but should not be making decisions for the direction of the research. Typically, consultants will charge a fixed fully burdened rate for their services (i.e. $250/hour)

Consultant services are budgeted as a direct charge in the “Other” category.

Consultant Services need to be justified in the budget narrative.

Notes:

• UF faculty may not be paid as consultants from UF sponsored projects. UF faculty devoting time to a sponsored project should be budgeted for in the personnel line with the appropriate amount salary and fringe corresponding to the effort devoted to the project.
• Intra-UF consulting undertaken by and between faculty is a University of Florida expectation for collaborations to occur without additional compensation.
• Federal employees may not be paid from federal funds.

NIH recognized that DMS costs may be requested in many cost categories. Applications submitted for due dates on/after October 5, 2023, will no longer require the use of the single DMS cost line item.

NIH will require applicants to specify estimated DMS cost details within the “Budget Justification” attachment of the R&R Budget Form or “Additional Narrative Justification” attachment of the PHS 398 Modular Budget Form, pursuant to the instructions. View the NIH Announcement.

Proposal budgets should include estimated funds needed for data management and sharing activities. These should include all allowable costs for DMS for all data types. Best practice is to plan on full storage costs being incurred during the period of performance, even for scientific data and metadata preserved and shared beyond the award period. Reasonable, allowable costs should be included in NIH budget requests when associated with:

Equipment is an item that meets all of the following criteria:

• Has an acquisition cost of $5000 or more. Includes: Invoice amount, sales tax, freight costs, installation costs, and other cost incurred to acquire; less trade or trade in discounts and/or educational allowances. Excludes: insurance, maintenance and service contracts and warranty costs, and
• Has normal expected life of 1 year or more
• Note: HiperGator hardware should be budgeted as equipment while HiperGator services should be budgeted under Other Direct Costs.

Rental of Equipment should be budgeted not as equipment but as an Other Direct Costs and does incur F&A even using an MTDC base. The UFIRST Category “Rental/User Fee – Equipment or Facility” should NOT be used for equipment rental.

UG Sections 200.453 (c)

The Uniform Guidance allows the direct charging of computing devices, costing less than  $5,000 as a material and supply cost provided they are essential ❶ and allocable to the project. Computing devices do not have to be solely dedicated to the performance of a federal award, in order to be charged 100% to a single award or allocated to several awards. Computer devises are expected to be primarily used to support the performance of the federal award.

❶ UF considers essential to mean: Computer devices and accessories that are necessary for the performance of the project or activity being supported by the federal award. Examples of essential, might include: (1) used to acquire, store, analyze, process, and publish data necessary for the performance of the project or activity; (2) used to create information electronically, including printing, transmitting, receiving and visualizing the information in support of the performance of the project or activity; (3) used in training, instruction, or curriculum development activities funded by the federal award; or (4) other circumstances demonstrated as essential.

Budgeting: If you believe computer devices and/or accessories are essential and allocable to the performance of your project and meets the conditions above, you should budget for the computer devices and/or accessories and provide in the budget justification a narrative that explains how the items are essential to the performance of the project.

In the case of NIH Modular Grant applications, computing devices and/or accessories should be itemized and justified in the detailed budget and justification provided to UF.

CAS Exemption Needed: If awarded, UF will require a CAS exemption form be completed, reviewed, and approved for any computer devices and accessories costing less than $5,000, budgeted or not.  Budgets that include computer devices and/or accessories that have been justified as essential will assist and expedite the CAS Exemption request.

Materials and supplies necessary for the performance of the work may be budgeted for as direct costs.

Also see Budgeting for Computing Devices as a Direct Cost above.

Direct charging of general office supplies should be restricted to projects with a high demand for these items and must be in compliance with the university’s Cost Accounting Standards (CAS) policy; all such charges must be project-specific and justified in the budget. Even though supplies are estimations, it is advisable to have a breakdown of these items by general classification as substantial amounts are usually challenged by sponsor reviewers.

Travel charges may include airfare, hotel charges, taxis, visas, passports, entry or exit taxes, per diems and rental cars. Most sponsors require (in the budget justification section) the purpose, destination and time span for each trip, and the number of individuals for whom funds are requested. This must be fully explained, noting the relationship of the trip to the project. Sponsored research funds are subject to both sponsor and State of Florida rules and regulations. Domestic and foreign travel have some differences:

Domestic Travel

Domestic travel reimbursements are subject to the state’s travel regulations and payment rates. Out-of-state travel should be requested on the basis of actual expenses for lodging and round trip economy airfare. Meals for State of Florida employees are reimbursed using the State per diem rate. In addition, some sponsors may have set fixed maximum per diem limits. Reimbursement for any trip which includes both in and out-of-state travel should be requested on the basis of as close an estimate as possible.

Foreign Travel

Foreign travel requests must specify the destination. The U.S. Department of State’s foreign per diem and hotel plus meal payment rates should be used. In today’s funding environment, it may not be possible for a Sponsor to cover travel for conference attendance unless there is active involvement of the faculty in the program to present, and/or unless the meeting has direct relevance to the research project. Typically, for international travel, only American flag carriers may be used. Sponsor Prior Approval may be required for foreign travel.

Travel Information is also available online, http://fa.ufl.edu.

Patient care costs are defined by NIH as: “Research patient-care costs are the costs of routine and ancillary services provided by hospitals to individuals participating in research programs. The costs of these services normally are assigned to specific research projects through the development and application of research patient-care rates or amounts (hereafter “rates”)”.

Indicate in detail the basis for estimating costs in this category, including the number of patient days, estimated cost per day, and cost per test or treatment. If both in-patient and out-patient costs are requested, provide information for each separately. If multiple sites are to be used, provide the information by detail by site.

Research patient-care costs do not include:

1.) the otherwise allowable items of personal expense reimbursement, such as patient travel or subsistence, consulting physician fees, or any other direct payments related to all classes of individuals, including inpatients, outpatients, subjects, volunteers, and donors;

2.) costs of ancillary tests performed in facilities outside the hospital on a fee-for-service basis (e.g., in an independent, privately owned laboratory) or laboratory tests performed at a medical school/university not associated with a hospital routine or ancillary service;

3.) recruitment or retention fees; or

4.) the data management or statistical analysis of clinical research results

Here are some helpful definitions from the NIH Grants Policy Statement:

• Routine Services: Regular room services, minor medical and surgical supplies, and the use of equipment and facilities, for which a separate charge is not customarily made.
• Ancillary Services: Those special services for which charges are customarily made in addition to routine services, e.g., x-ray, operating room, laboratory, pharmacy, blood bank, and pathology.
• Outpatient Services: Services rendered to subjects/volunteers/donors who are not hospitalized.
• Usual Patient Care: Items and services (routine and ancillary) ordinarily furnished in the treatment of patients by providers of patient care under the supervision of the physician or other responsible health professional. Such items or services may be diagnostic, therapeutic, rehabilitative, medical, psychiatric, or any other related professional health services. These expenses are for care that would have been incurred even if the research study did not exist. The patient and/or third-party insurance generally will provide for reimbursement of charges for “usual patient care” as opposed to not reimbursing those charges generated solely because of participation in a research protocol.

FAQ’s:

1. What about lab work or procedures done by a hospital that is NOT Shands? Are these considered patient care?
   • Each hospital must develop its own patient‐care rates, which usually are their Medicare rates for each specific service it provides to research subjects. These costs would be considered allowable patient‐care costs.
2. What about lab work that is sent to a non‐hospital lab?
   • Per the NIH policy, costs of ancillary tests performed outside the hospital on a fee‐for‐service basis by an independent, privately owned laboratory or performed at a medical school/university (UF) laboratory (Quest, CTSI, CRC, AMRIS etc.) are NOT considered patient‐care.
3. What about professional fees for medical procedures (UFP)?
   • Per the NIH policy, patient‐care costs do not include consulting physician fees. Ordinarily, physicians who are named as co‐investigators or other key persons on a project will be compensated through their effort on the project, fulfilling their time as part of their professorial duties to conduct research.
   • UF Professional fees do not meet the definition of patient‐care costs.
   • UF expects that when professionals are identified as participating on an NIH grant submission, their professional services are presented in the budget with appropriate effort and salary compensation.
   • Shands Technical fees meet the definition of patient‐care costs.

Helpful Hints: If Shands bills for the medical services, these services are patient‐care costs; if UF bills for medical services, these are non‐patient‐care costs. For example, an MRI or a blood draw provided at Shands or its clinics is a patient‐care cost; an MRI at the McKnight Brain Institute or a blood draw in UF research space is a non‐patient‐care cost. The term patient care may include services, such as a blood draw, that are not strictly “care” of the patient but would meet the NIH definition of patient‐care costs.

Recommendation at Proposal Stage: if you are unsure of where the services will be performed, include the costs in the ‘Other’ section of your budget.

4. What about research subject specimens that UF receives from another clinical site to be tested at UF?
   • As these tests would not be conducted by Shands laboratory and the specimens are not from UF’s subjects, they would not be considered patient‐care costs.
5. What about the maintenance, administrative overhead, record retention and dispensing charges from Investigational Drug Services (IDS)?
   • When we are paying IDS directly (i.e account numbers that begin with “Shands” or “IDS” prefix on your quote/invoice), the costs to dispense the drugs from IDS for our participants would be considered patient care costs. For account numbers that begin with “UF” or “CRC” or “ONC” prefix, these would not be considered patient care costs as you are not paying IDS directly. Protocol maintenance, administrative overhead and record retention costs would not be considered patient care costs.
6. What about the imaging CD I need from Radiology for the protocol required CT scan?
   • The CD would not be considered patient care costs.
7. What about the required UF Staff health assessments at the Student Health Center needed in order to work on a particular study?
   • These are not considered patient care costs.

REMINDER: The PI must seek prior approval from the NIH program officer when there is a significant change in scope of work. UF does not consider re‐budgeting categories for a change in the service location (from UF to Shands or vice versa) as a change in scope. The change of location of services can result in an increase/decrease of patient care costs and if the F&A base is MTDC could result in an increase in F&A charged to the project. This change may require change in R99 status for Shands billing.

Facility alterations and/or renovation (A&R) cost must be specifically budgeted for and approved by the sponsor. A&R costs are allowable if necessary for the performance of the project. One example is altering a room to make space for a new grant-related piece of equipment. Justify basis for costs in detail. Provide the square footage and costs. If A&R costs are in excess of $500,000 it would be considered a”construction” project and not allowable under traditional grants.

You should coordinate pricing with UF’s Planning, Design, Construction Unit.

Please see the detailed description of participant support costs and how to budget for these costs on the DSP website at https://research.ufl.edu/dsp/proposals/budgeting/participant-support-costs.html.

The University recovers the cost of maintenance of facilities, space, equipment and other assets through the “Facilities” portion of the Facilities & Administration rate. Uniform Guidance (2 CFR 200) mandates that no cost can be both direct charged to a grant and included in the F portion of the F&A rate development. Therefore, internal charges between departments for use of facilities and equipment must be scrutinized to ensure UF does not charge sponsors for the same asset twice. To ensure this does not occur, follow the costing guidance below:

The Rental/User Fees category should be used when renting or leasing facility or space is required for project implementation, and the facility or space is not owned by UF.
NOTE: If rental in non-UF facilities or space (not equipment) is budgeted for AND the majority of the project occurs in these facilities, the project may qualify for the off campus F&A rate.

The Other Expenses category should be used when a facility, space or equipment is owned by UF and an approved Auxiliary (EBA) Rate is in place for the facility, space or equipment. The owner/operator of the facility, space or equipment should provide you documentation of the approved rates as you are preparing your budget. Examples include the ICBR and ACS core services.

When facility/building space is owned by UF and no approved Auxiliary (EBA) Rate is in place, only direct costs associated with running or using the space or equipment may be included on the budget as direct charges. These charges may only include reimbursable expenses such as personnel time, materials and supplies, fuel, etc. Direct charges may not include any maintenance or depreciation on the already UF owned asset.
• When budgeting for these items on a grant proposal, it is acceptable to use a flat rate which is not broken out into reimbursable expenses, depending on the level of detail that is required by the sponsor. However, when these costs are charged to the grant, they must be broken out. If there is not an approved auxiliary rate, no flat rate may be charged to the grant.
• Example: A PI would like to use a greenhouse which is owned by another department at UF. There is not a UF approved EBA/auxiliary rate in place for use of the greenhouse. The PI could budget for purchasing plants and fertilizers for the project, and for paying greenhouse staff to care for her plants. She could not budget for electricity or water use, or maintenance for the greenhouse.
• Example: The University owns a boat which is used by many faculty to access remote field sites. There is not a UF approved EBA/auxiliary rate in place for the use of the boat. The PI could budget for the hourly rate of the ship’s captain and fuel but not for a flat rate for the maintenance and depreciation of the boat.

Equipment rental from non-UF owners should be budgeted as Other Direct costs and is subject to F&A even when the MTDC base is used. The UFIRST Category “Rental/User Fee – Equipment or Facility” should NOT be used for equipment rental.