Issue in question
UKRO has recently received several subscriber queries relating to the eligibility of PhD fees and bursaries/fellowships/scholarships or stipends for students working on Horizon 2020 projects and to the calculation of hourly rates for students.
Whilst in the UK national context PhD students are often not considered employees, for the purposes of their participation in Horizon 2020 projects, the same rules apply to them when calculating their hourly rates and for reporting purposes (i.e. keeping time records, or signing a declaration on exclusive work on the action).
Clarification
PhD student tuition fees and bursaries can be charged as an eligible personnel cost, providing that the students are exempt from paying the said fees, and provided that the student’s contract specifically mentions the waived fee amount. The full stipend payment, including the waived fee, must be also clearly recorded in the universities’ accounts for audit trail purposes.
In this context, fellowships/scholarships/stipends and the waived fees are assimilated to salaries provided that this remuneration complies with the national law on tax and social security payments.
As with the calculation of personnel costs for employees, the hourly rate for PhD students must be calculated in accordance with the method (monthly or annual) stated in the grant agreement. For example, if the contract, collective labour agreement, national law, etc. does not allow to determine how many hours the person works for the beneficiary, Option 1 (1720 hours) for productive hours must be used to calculate the hourly rate.
In terms of record keeping, where a student is not working 100% on the project, only the percentage of FTE worked can be charged to the project and time records need to be provided.
The Annotated Model Grant Agreement (AMGA) (PDF) provides further clarification on page 50, stating that costs of students that work for the beneficiary can be accepted, if the agreement is work-oriented (not training-oriented: i.e. not aimed at helping the student to acquire professional skills). PhD agreements can be considered work-oriented, however, time for training (if any) may not be charged to the project.
Fellowships / scholarships / stipends can be charged to the project as personnel costs, if:
- the remuneration complies with the application national law on tax and social security
- the assignment of tasks respects the laws in force in the country of the beneficiary
- the students have the necessary qualifications to carry out the tasks allocated to them.
Cost for exemptions from academic fees (or part of them) are eligible as personnel cost, if the student’s contract includes the amount of waived fees as part of his/her remuneration. The other conditions set out in Article 6 of the Model Grant Agreement have to be fulfilled as well (e.g. the full remuneration, including the value of the waived fees, must be recorded in the university’s accounts).
Marie Skłodowska-Curie Actions (MSCA)
Specific rules apply to PhD candidates (fellows) participating in the Marie Skłodowska-Curie Actions Innovative Training Networks (ITNs), which use the MSCA-specific unit cost model. Under no circumstances can tuition fees be charged to the fellows. MSCA-ITN researchers may NOT be requested to pay tuition fees for their research training and/or PhD programme from their own funds or from the researcher unit costs that they receive. The costs, which are usually covered by such tuition fees (e.g. student registration, access to student services (library, computing, etc.), teaching, supervision, examination and graduation) can be reimbursed under category B ‘institutional costs’. Further information on eligible and ineligible costs for MSCA ITN projects is provided on page 452 of the Annotated Model Grant Agreement (PDF).