Duke-based guidance on NIH Allowable Costs to improve human participation and inclusion

The NIH released a notice expanding allowable costs for participant engagement in human participant research. The below information is based on NIH guidance, and expanded to illustrate how these types of costs can or cannot be handled at Duke. In consultation with the specific NOA, this information can help research teams outside of NIH funding properly budget and plan during the pre-award period, and process transactions post-award.

Departments should carefully evaluate both the type and purpose or use of each expense to determine the best way to allocate it to the grant. There are often several avenues available for expensing allowable items. The principle of direct costing should guide the selection of the most appropriate avenue, ensuring it fits the specific needs of the grant and the research activity.

For questions about the below, please reach out to the project’s grant manager, or the appropriate central office.
For information about processing payments to research participants, see GAP 200.420.
For general guidance on participant management and payment, access the myRESEARCHpath Topic Page.

NIH Activity Descriptions		Duke Related Resources
Item	Examples	Duke Guidance	Special Considerations/Notes
Advertising and Public Relations	Advertising: community activities to communicate the grant-supported research activities, such as creating/ distributing flyers to advertise a research study. Public relations: townhalls, press interviews, or other meetings to discuss grant-supported research activities and their results.	Pre-Award: Anticipated costs must be detailed in the proposal budget and justification. For help including these costs in your budget see: Develop the budget and justification Federally sponsored budgets	The budget justification is a detailed explanation of the budget in narrative form. The justification needs to carefully explain all expenses to show that each item is necessary for the successful completion of the project.
Advertising and Public Relations		Post-Award: These types of expenses should be charged to the G/L that most accurately identifies the expense. There are a variety of G/L accounts that could be utilized depending on the expense and the purpose of the purchase. For information on how to correctly charge these expenses see: GAP 200.320	G/L 693200: Public Relations and Social Expenses; costs for public relations and social expenses, including alcoholic beverages are not allowable in support of Federal programs. An alternative appropriate G/L must be used.
Child Care Costs	Providing childcare at the research site or reimbursing expenses which are necessary for childcare.	Pre-award: Anticipated costs must be detailed in the proposal budget and justification, and in the consent form. If childcare costs would be expected for all participants, anticipated childcare expenses may be included in general incentives for participation in the study. Develop the budget and justification	The budget justification and the consent form must articulate reimbursement limits that align with study visit duration and typical childcare rates (i.e., reimbursement for up to 4 hours of childcare at $15/hr).
Child Care Costs		Post-award: Childcare services enable and encourage research participation and should therefore be charged to G/L 622500.
Incentive Costs	A gift card to volunteers or patients participating in an NIH-funded research study.	Generally if a gift card is an incentive for participating in a research program, then these expenses should be charged to G/L 622500 for Experimental Subject Payments. For information on how to charge these expenses see: GAP 200.420	For more information see: Manage research participants
Meals	Providing meals to compensate participants for time spent on grant-supported research activities.	Pre-Award: All anticipated meals should be included in the proposal budget. Post-Award: Most meals for research purposes (including meals provided as part of an approved research function) should use G/L 696000 - Meetings: Business Related.	Research teams should consider the purpose of a meal when deciding which G/L to use. Some examples are: Providing snacks to a research participant during participation in a study. This would fall under G/L 696000. Providing refreshments for community members taking part in planned Research/Community Advisory Board meetings. This would fall under G/L 696000. Unless budgeted in advance, the purchase of meals or refreshments for internal (i.e., Duke staff) project meetings is typically not allowable. Allowable expenses must be tied directly to grant-supported activities.
Nursery Items	Providing toys, books, and other items to make waiting rooms/waiting times more conducive to children of research participants. Note: Recipients should consider using this item in conjunction with allowable childcare costs (see the item above).	Toys/books/small incentives provided to research participants may be expensed to G/L 622500.
Pre-Award (Pre-Agreement) Costs	Recipients at their own risk may consider if pre-award costs may be appropriate to initiate research planning activities prior to receiving the Notice of Award (NoA), such as fostering community relationships or establishing scientific, advisory, and other committees.	Refer to: Understanding pre-award activities and spending	Requesting a WBSE in advance of receiving the award is an option to record all project related expenses as work may begin prior to receipt of a fully executed agreement. The risks, liabilities and limitations associated with pre-award spending must be carefully considered prior to requesting approval to spend funds in advance of receiving the award. Refer to pre-award spending guidance for additional information.
Publication and Printing Costs	Creating participant and/or community media outreach, such as brochures, or newsletters, to provide research updates and opportunities for participation.	Pre-Award: Anticipated costs must be detailed in the proposal and must explain all expenses illustrating that each item is necessary for successful completion of the project. For help including these costs in your budget see: Develop the budget and justification Federally sponsored budgets	Consider the item or service being purchased and the purpose of the item or service when deciding which G/L to use. For example: Cost of posting research opportunities to a social media platform would fall under G/L 690200 Advertising and Publicity
Publication and Printing Costs		Post-Award: These types of expenses should be charged to the G/L that most accurately identifies the expense. There are a variety of G/L accounts that could be used depending on the expense and the purpose of the purchase. For information on how to correctly charge these expenses see: GAP 200.320
Research Patient Care	Clinical services that are included in the research activities or protocol, such as blood draws or imaging.	The following G/L should be used to record the cost of medical services rendered to outpatients for which a Duke department has assumed responsibility: G/L 696400 Out-Patient Care	The department overseeing the grant is responsible for making sure costs are correctly allocated to the appropriate G/L. Since hospital staff, who may not be familiar with research administration policies, often provide these services, please take a moment to double-check your ledger after expenses are incurred.
Travel/ Research Participants	Reimbursing participants for transportation costs to the site of the research study (e.g. location where the participant have study visit as part of the grant-supported research). Setting up a system to transport study participants for grant-supported research visits.	You can reimburse participants for mileage and parking. For the specific G/L please refer to: • G/L series 6225XX	Information about research staff purchasing parking/bus passes can be found here.