Hi AMMRL,
Thanks to all of you who responded to my query about assistance charges and
rules for NMR facility charges. The topic of NMR charges brings up so many
issues/questions, but Iım trying to stick to my original questions (repeated
at the end) for this summary.
Margaret
Total responses: 21
US: 17
Canadian: 4
Origin of charging rules used: US government rules: 9 University
rules: 6 Other, or not clear: 6
(Note: Some university rules are most likely based on the US gov rules.)
Charge for assistance: 12
(Sometimes this is a separate charge for assistance, and sometimes part of
an hourly rate for spectrometer time.)
Waive assistance charges for collaborations (co-authorship, or possible
co-authorship): 4
Apply larger assistance charges to ³outsiders² (generally people from
outside the university): 4
Additional comments:
In some facilities assistance charges are the same for all users; in others
they apply only to certain groups or are higher for certain groups.
A reason for not charging for assistance is to encourage users to seek help.
Some charge for training, but most do not. Managers want users to be well
trained and also users have some tendency to avoid paying charges, at least
that they find excessive. Clearly, where training is being charged, the
culture is different and users do not have a problem with paying for it.
There is an issue, apart from the considerations of rules of charging taken
up below, of managers being aware of what their market can bear. Charges
for assistance or for hourly time can only be raised so much before users
are likely to revolt and either do less work or refuse to pay.
The rules (for the US; unsure of similar documents in Canada?):
The most important document for US universities is the US Office of
Management and Budget circular A-21 (05-10-04), as a few respondents
mentioned. On the OMB website this can be downloaded, along with Title 2 CFR
220, which is the location of A-21 (unchanged text) since 08-31-05.
Iıll just copy from the response of Josh Kurutz with the links:
³I recall the most iron-clad regulations for core facilities are found two
key OMB circulars:
€ A-21 (Cost Principles for Educational Institutions):
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A21/a21_
2004.pdf
<
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A21/a21
_2004.pdf>
and
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A110/2cf
r215-0.pdf
<
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A110/2c
fr215-0.pdf> (page 68)
€ A-110 (Uniform Administrative Requirements for Grants and Agreements With
Institutions of Higher Education, Hospitals, and Other Non-Profit
Organizations):
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A110/2cf
r215-0.pdf
<
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A110/2c
fr215-0.pdf> (page 39)
Here is another document with brief guidance covering ³Specialized Service
Facilities²:
https://www.gpo.gov/fdsys/pkg/CFR-2014-title2-vol1/pdf/CFR-2014-title2-vol1-
sec200-468.pdf
<
https://www.gpo.gov/fdsys/pkg/CFR-2014-title2-vol1/pdf/CFR-2014-title2-vol1
-sec200-468.pdf>
Also, Northwestern has posted a powerpoint that was given to its core
facility staff:
https://www.northwestern.edu/coststudies/docs/NURAP_RechargeCenters_CoreFaci
lities2.pdf
<
https://www.northwestern.edu/coststudies/docs/NURAP_RechargeCenters_CoreFac
ilities2.pdf>
³
Also, Binghamton University has a nice document and an Excel spreadsheet for
calculation of rates that could be modified for use at other universities,
as pointed out by Jürgen Schulte:
https://www.binghamton.edu/business-office/accounting/chargebacks.html
<
https://www.binghamton.edu/business-office/accounting/chargebacks.html>
General outlines of the rules are (not complete):
1. The US government applies these rules in cases where it has funded
the equipment in the facility, and/or funded grants that pay for usage of
the facility. The government does not want its pocket picked, so requires
that charges not be excessive and the facility not make a profit.
2. The facility needs to review its budget at least every 2 years
(some do it yearly), as this budget forms the basis of the calculation of
rates that will be charged. Since the income and expenses can change over
time, the admonition to not make a profit has to be taken to mean breaking
even over a period of years, some possibly with surplus and some with
deficit.
3. Different groups that pay different rates, either for hourly
charges or assistance charges, can be set up, but they need to be justified
by the subsidy or lack of subsidy the group provides. It seems very common
to have two groups of academic users, inside and outside the university
where the facility is located, but other divisions, including making a host
department that houses the facility a group, are possible.
4. Other more complicated thingsŠ.
Without getting into trouble (?), Iıll say it may be the case that some of
us have engaged in more rigorous compliance with these rules, including
active engagement with our accounting or sponsored projects department in
setting rates, while others of us may not be so rigorous. No doubt we all
have accounting and sponsored projects departments that keep an eye on us
and would raise a red flag if we turned up surpluses many years in row, but
most of us tend to be pretty much breaking even and never raise this flag.
Still, it is good for us to look into the rules, at least when any rate
changes are contemplated. Being audited and found out of compliance is a bad
experience, to be avoided.
Several respondents who seem to have had experience with the more rigorous
interface with the rules, who may be useful resources for the rest of us to
ask questions are:
Josh Kurutz jkurutz_at_alumni.caltech.edu <jkurutz_at_alumni.caltech.edu>
Martha Morton mmorton4_at_unl.edu
John Wilderman John.Wilderman_at_unh.edu
David Vander Velde davidv_at_caltech.edu <mailto:davidv_at_caltech.edu>
Jürgen Schulte schulte_at_binghamton.edu <schulte_at_binghamton.edu>
Daniel Plant dplant_at_ufl.edu <mailto:dplant_at_ufl.edu>
Karen Ann Smith karenann_at_unm.edu
My original question:
This question is about rules for charging for NMR usage and services. Iıll
break it up into a few separate questions:
1. Does your facility follow any written set of rules on charging
users, and if so what is the origin of the rules? For example, did they
come from a federal granting agency or from your institutionıs
accounting department?
2. Do you ever charge for time other than usage time on spectrometers,
such as time for consulting, setting up and running experiments,
working up data, interpreting data, or writing reports for users?
3. If you do charge for time as in Q2, are there rules that only allow
certain users to be required to pay these charges? That is, are users
categorized by being in a certain group of some kind, department, or
institution, with some categories paying for assistance and others not?
What are the categories, rules for charges, and reasons behind them?
If anyone has a bulletproof (legal, approved by agencies and accountants...)
written document of requirements for how to make NMR facility charges, I
would appreciate seeing that and also knowing its origin(s). I will
summarize responses. Thanks.
Received on Tue May 15 2018 - 08:26:10 MST