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My NSF award runs out in a several months. It still has funds budgeted for conference travel. I cannot find any conferences that would be strongly tied to the work. However there is one I would like to attend (too late to submit abstract) but not connected with the award very well. I would be able to network there with collaborators and presumably discuss the research related to the award which would lead to progress on the project. Would using the grant to attend the conference be unethical?

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    If a conference is one where you "would be able to network there with collaborators and presumably discuss the research related to the award which would lead to progress on the project" I do not understand why you are labeling it "marginally related". I also don't quite believe that it's possible that there is any fundable research project that has no relevant conference at all.
    – Bryan Krause
    Commented Jun 19 at 12:38
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    As far as I know, the NSF requires that expenditures of grant funds be for furtherance of the research for which the grant was awarded. (For example, I was told that buying books with NSF grant funds is OK as long as the books are relevant to the project.) In your case, the plan to meet collaborators and discuss research related to the award seems sufficient to satisfy this NSF requirement. Commented Jun 19 at 15:57
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    Please avoid answering in the comments. There is an excellent, nuanced real answer below.
    – cag51
    Commented Jun 20 at 3:41
  • You asked two very different questions. Do you want to know if this is an allowable expense, or do you want to know if this is ethical? Commented Jun 20 at 14:07
  • @TerryLoring When would spending an allowable expense be unethical? Commented Jun 21 at 21:10

4 Answers 4

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Research administrator here, who approves expenses like these every day. The actual answer has to do with your institution's policies. In the event of an audit, if your institution is more restrictive than the government and prevents this type of purpose to be allocable to a grant, then it's not allowable. Let's say your institution has a posted policy that conferences on sponsored funding must be for the purposes of disseminating research results. That is more restrictive than the federal government, but that is the choice of the institution. If the charge hits the grant in violation of that policy, your institution can have a finding in their audit, even though the sponsor doesn't care. So the first thing is that you need to talk to a research administrator at your institution.

Secondly, the question I always ask PIs is whether or not this will be embarrassing to put on the progress report and explain to the program officer (PO). If you find yourself squeamish about explaining how it directly benefited the project, don't put it on there. Otherwise, at the time of reimbursement, make a statement as to how the trip benefited the grant. That's what makes it "allocable". The exact allocation methodology may be dictated by local policy. E.g., I sometimes force a percentage of such expenses onto discretionary funds because the sole purpose was not the grant. That's not a sponsor policy, that's me apply cost principles outlined in Uniform Guidance (UG), a section of the Code of Federal Regulations, which nearly all federal grants are required to abide by. You won't see all the rules for UG in your terms and conditions; you have to know that it's included as part of NSF general terms and conditions, and then know how to read the regulations. Usually your institution should do this for you, they then incorporate such things into their own policies, so if you follow the policies you are following the laws.

Generally speaking though, if I were your approver, given what you stated, I would deny the reimbursement without a strong explanation as to how this benefited the grant. Looking at 2 CFR 200.403(a), and I am already stuck on whether or not you meet this requirement, "Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles." The first rule of spending sponsored funding is that you cannot spend the money because funds are running out. You have to prove to me that the cost stands alone. The way that you are hedging here suggests that you are trying to spend the money more than thinking of the benefit to the grant first.

You can look up "cost principles" at different universities and see similar language on how approvers are guided based on the requirements from Uniform Guidance. Here's an example from University of Washington. These are all directly sourced from 2 CFR Part 200 Subpart E - Basic Considerations.

If you want this to go on your grant, come up with a strong justification as to how it benefits the grant, and also make sure you can explain why 100% of it goes on the grant and shouldn't be split with discretionary or another sponsored fund. See 2 CFR 200.405. It also needs to be listed in your progress report (RPPR). If you don't want to list it in your RPPR, it's not allocable to the award.

This type of networking use of conferences is very popular in CS because so many collaborators end up in the same location, it's so much easier to have in person meetings at conferences than traveling to another person's site. But prior to approving such an expense, my PIs have to provide me with a more robust explanation -- e.g., I make them name who the people are that they are meeting, and how that relationship benefits the grant. In the case of my PIs, I usually know who their friends are, so when I see "Dr. Jones from Example University" listed, I know that they publish with that person all the time. It is no longer sketchy because we took the time to do a thorough job showing the benefit to the grant, including the adequate documentation (2 CFR 200.403(g)).

ETA 2: To address some confusion in the comments, when it comes to proving something is related to the scope of work, the PI needs to declare the relatedness to the expense approver and provide any required documentation per the institution's policies. In the event that this declaration were later proven to be fraud, the university would be protected because of the attestation, and the PI could face personal consequences for lying and intending to defraud. If the university approves without requiring attestation and appropriate documentation, they are at fault in the audit due to lack of internal controls. Individual institutions deal with this situation differently. Mine would charge someone's discretionary for all costs that needed to be removed, but that is just one example.

In 2020, NSF OIG special agent, Maureen Weir, wrote in NCURA magazine, "Detecting and Preventing Grant Fraud":

Red flags for fraud may include excess spending in a given budget category, charging expenses that are unrelated to an award’s purpose, charging unrelated research to an award to spend down the funds, and continuing to spend funds after the end of an award. Issues often arise when a university does not have adequate controls in place or faculty and staff are not following university policies.

NIH OIG fined University of Nevada, Las Vegas $1.4M partly due to travel expenses:

OIG further alleged that the NIH awards were improperly charged for the salary and fringe benefits of the PI without adequate documentation, and for the travel and associated costs of at least two trips to Nigeria that were unallowable because there was no evidence that the trip was in furtherance of the NIH-funded research.

Administrators will trust that PIs are not lying to them at the time of approval, but requiring attestation at the time that the expense is approved shifts the legal accountability to the PI.

ETA 1: Including an example of a travel-related audit finding from NSF for Dartmouth College (publicly available on NSF's website).

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    "I make them name who the people are that they are meeting, and how that relationship benefits the grant." - as the OP is already mentioning "collaborators", they may actually have concrete people in mind, but I wonder: Generally, isn't the entire point of "networking" at a conference that you meet (= get to know) people you do not know beforehand, and discover previously unforeseen avenues for your current research topics? If you already know who you want to meet and what to talk about, it would seem there are much cheaper ways to achieve that than attending a conference. Commented Jun 19 at 21:20
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    @O.R.Mapper - so some institutions would disallow attending a conference for general knowledge right off the bat; it's their prerogative to do that. Also, the explanation given to me is that "we are all going to be at X conference, so it makes sense to meet about our work while there instead of having another trip across the country". Thus we are coding the conference as partially a scientific meeting to help advance the project. This matters more for collaborative research projects. Sometimes this type of thing is written into the collaboration plan and is thus approved by the sponsor. Commented Jun 19 at 21:49
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    What's the point of showing the audit? Those denials, cancelled travel, premium airfare, receipt discrepancy, have nothing to do with OP's question.
    – user71659
    Commented Jun 20 at 2:24
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    @yourfriendlyresearchadmin I disagree. All of those examples are bright-line, but OP's issue is far less clear. To me, it shows they'll only go after things they can point to a regulation about. You need to give an example where NSF charged back attendance at a legitimate conference for the reason it wasn't closely related. Until then, it's speculation.
    – user71659
    Commented Jun 20 at 3:08
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    @yourfriendlyresearchadmin Example 1: supports my point again. Refunded costs are clear, no argument here. Reading between the lines, can't bring your wife. Example 2: same, the conference wasn't an issue, it was his obvious side consultant gig. None of these are judgement issues with the conference, they're issues with receipts, extended stays, and other travelers, all red flags. NSF says you should be doing interdisciplinary research.
    – user71659
    Commented Jun 20 at 4:21
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SHORT ANSWER:

  1. I see absolutely NO ethical issue in using money from a grant awarded to you for a research topic X in order to attend a conference about research topic Y, especially if that might be your next topic of interest, and especially if the conference is gathering people in the same general research area.
  2. Discussing it informally with the head of your department might alleviate your doubts more efficiently than discussing it with strangers on https://academia.stackexchange.com/!

LONGER ANSWER:

  • What is ethical or not is evolving over time and varying from one culture to the other, ethical rules are inherently social ones, the ones that a community collectively agrees to enforce and to follow for the benefit of the community as a whole. Maybe in the future or within a specific context (with scarcer resources) the answer will be different, but for now and in the academic contexts I know (European, North American and South American universities), I am reasonably sure that there is absolutely no ethical problem with what you describe.

  • Strangers on https://academia.stackexchange.com/ might be representative or not of the views of people in academia at the international level, which is only one of the communities to which you belong, and not the most critical one for the advancement of your career. Better discuss it (informally because it is not important enough an issue) with colleagues in your department, and ideally the head of your department.

  • In any case, paying someone to check whether topic Y is related enough to topic X to justify using funds awarded for results on X in order to pursue Y for all uses of all grant money over the world would probably be more costly that the few misused of that money, so I doubt that anyone is checking the relevance of the topics of the conferences where you go.

Hope it helps! If you enjoy the conference and make the world a better place, it will be a good use of the resources of your grant!

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    This is not good advice, particularly about spending on topic Y for a grant on topic X. That violates the scope of work. Please do not do this. Grants come with a host of terms and conditions, and if you violate them, you can open your entire institution up to a federal audit. If you are not sufficiently convinced, please read the public NSF audits of many institutions: oig.nsf.gov/reports-publications/reports/audit We are talking multi-million $ DOJ settlements. In 2008 Yale paid out $7.6 million over effort reporting. That's why 100% effort for "summer salary" went away. Commented Jun 19 at 18:30
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In my opinion, the grant/fellowship funds the science and the scientist/applicant - the two are closely linked and intertwined. If you think this is a legit and useful conference that will benefit you and your research in the short and/or long term (so not just two weeks on a tropical island for a fake conference), then it is very well defendable and explainable that this would not be unethical.

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    The problem with this answer is that it actually suggests the opposite. If I can't untangle the conference from the PI, i.e., it represents "all their work", then it should go on discretionary. This is per federal law 2 CFR 200.405. You have to directly prove it's allocable to the award you indicate and defend the percentage you choose. If you can't adequately defend and document a percentage, it's not directly allocable. Commented Jun 19 at 18:20
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    But then what is considered sufficient proof? Let's say if one only attends (and not presents their work related to the award) as would be the case in this question? I agree that if no argument can be made then it's a problem, but what is 'sufficiently related' if there is no hard evidence of "I am presenting the work I said I would do in aim 1"? I'm genuinely curious.
    – BioBrains
    Commented Jun 19 at 20:20
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    this is always a judgment call. The institution puts people like me in place to make such calls. Also the institutions make their own policies based on what they perceive the risk to be. UW states "If no formal presentation was made, or the traveler was only attending the conference/workshop, written documentation should include the business purpose of the travel, which includes the benefit to the Award, and a copy of the agenda or schedule as available." This is how they want to handle the risk. I see Depaul and Harvard both have public guidance you can read for other examples. Commented Jun 19 at 20:39
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    @yourfriendlyresearchadmin Could you give an example of where you (or the funder) made a judgement call against the PI on technical details? The examples in your answer are essentially procedural (or fraud), not "Legit meeting X is not related enough to a grant on X'."
    – Matt
    Commented Jun 21 at 20:46
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    @Matt, so in the ETA 2 I mention that we require an attestation. If the grant says it's to study trees and the conference is about insects, I am going to ask a direct question, "can you please tell me how this benefits the grant with regard to the scope of work?" If they say, "why yes, this insect is killing trees, which is important for the objectives of this grant"--I take them at their word. Sometimes the question is unsettling and PIs pull back and say to put it on discretionary. I don't set myself up for a fight--I shift the liability to the PI away from the institution--that is my job. Commented Jun 21 at 21:00
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Expenses charged to a grant are supposed to specifically "benefit" (i.e., help advance) the aims of that particular project. Whether attending a particular conference does so is essentially a judgement call, which is why you're getting such conflicting answers. Fortunately, most universities offer researchers pretty wide latitude to use--and defend--your professional judgement.

Thus, it largely boils down to what you mean by "marginally related". At one extreme, you probably can't attend a conference in a totally different field: A physicist probably shouldn't attend an ornithology meeting just because they really like birds. However, it might be permissible if it is somehow connected to your research. For example, someone I knew in the Physics Department used the Advanced Photon Source (APS) at Argonne National Lab to study how the nanostructures of certain materials, including bird feathers, can produce colors without pigments. In this case, they'd probably have to write a "business purpose" justification. This is simply a short (paragraph or so) explaining how this does advance the grant's aims. For the feather stuff, they might explain how the session on birds' flight and preening habits will let them understand stresses on the materials and corresponding changes in their properties, which in turn informs the design of experiments for the remaining aims of the grant, etc etc.

In fact, you generally have to write business purposes justifications anyway; it's just easier for you (or someone else) when a pro forma one applies: "As described in the proposal, we attended Meeting X to present the results of Sub-project Y." As long as you can produce a reasonable justification, you should be fine and this is generally not a big deal. This is especially true for interdisciplinary conferences, where your topic might be represented but not the exclusive--or even primary focus--of the meeting. For example, if your grant is to study the molecular mechanisms of Parkinson's Disease, you should be okay to attend a conference on neurodegeneration or mitochondria (which are are thought to play a role in Parkinson's). Contra @yourfriendlyresearchadminstrator's answer, I have never seen expenses like this refused, on the grounds that while Conference A was related to the work, B or C would have been an even better fit. Plus, presentations by your collaborators (on this grant?) would seem to be prima face evidence that it is within the scope of the project.

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    I think we are largely in agreement. Though not sure about this part "on the grounds that while Conference A was related to the work, B or C would have been an even better fit". I don't go around looking for other sources to put it on; I make them attest to it being 100% related to one fund; then they often start to hedge, and then we have a conversation which results in a split. Something else for you to think about--the increasing focus on "overlap statements" is making it trickier to declare overlaps at the time of reimbursement--now that statement should go on current and pending docs. Commented Jun 21 at 21:07

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