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The HKS Research Appointment guidelines were revised in January 2010, prompted by guidance from OSP related to the charging of stipends to sponsored awards. The revisions were informed by federal guidelines (see below), but extend to all sources of funding: sponsored, gift, endowment, or unrestricted. The proper use of stipendee vs. employee categories must be followed regardless of the source of funds supporting the appointment.
For a detailed breakdown of the categories, consult our HKS Research Appointments Table of Categories. (HKS log-in required)
Stipends are payments made to individuals for subsistence support or to defray expenses during a period of academic appointment. These individuals are working on their own research and are paid without any expectation of work effort. Stipends do not reflect payments in exchange for services.
Sponsored research funds generally reimburse the University for the allowable cost of services rendered. If an individual is providing benefit to a project under the direction of a principal investigator, he or she should be paid as an employee (a Research Assistant if a graduate student, an Employee Postdoctoral Fellow, or an Employee Program/Department Fellow).
Stipends are allowable on sponsored awards only if the purpose of the agreement is to provide training to selected participants and the charge is approved by the sponsoring agency. Sponsored funds intended to support training or research training will state that intention clearly in the agency program announcement. The scope of work in the proposal and award agreements should also state explicitly that training or research training of specific individuals is a purpose of the award. In such cases, stipend expenses are expected and allowable.
Many non-federal sponsors are willing to fund stipends. It is important, however, to distinguish individuals who are providing services to the University from individuals who are being paid without any expectation of work effort. University human resources policies prevail over non-federal sponsor expectations. An individual who is being paid for the services he or she provides to the University should be considered either an employee or an independent contractor.
No explicit guidance exists in A-21 for the allowability of stipends, but the Circular does address student support. The only allowance for payments to individuals that do not represent compensation for services rendered appears in Section J.45, Scholarships and student aid costs, which says such payments are allowable “…only when the purpose of the sponsored agreement is to provide training to selected participants and the charge is approved by the sponsoring agency.”
Two sections of A-21, Section J10 and G, suggest that stipends should not be charged to research awards. First, Section J10 requires that amounts paid to individuals for their services on federal programs be effort reported, implying that payments to individuals which are not for services rendered should not be funded by research awards. Harvard’s effort reporting system does not include stipends, since these amounts do not represent compensation for work effort. And, Section G requires that the University include all modified total direct costs allocable to benefiting activities across its major functions in determining indirect costs. If funds used to support effort directly benefiting organized research are coded as stipends, these costs are excluded from the research base in violation of A-21.
The National Institutes of Health Grants Policy Statementstates explicitly that stipends are not allowable on research grants.
National Science Foundation
The National Science Foundation Grant Proposal Guideallows for stipends only in support of participant costs at conferences, symposia, workshops, or other specific training activities.
Given this clear guidance from NIH and NSF, Harvard’s two dominant federal sponsors, University policy follows this guidance for all federal awards, regardless of agency.