Controller’s Office phone: 413.545.1675
405
Memorandum
TO: Deans, Directors, Department
Heads and Principal Investigators
FROM: Andrew P. Mangels, Controller
DATE: May 2, 2006
SUBJECT: Additional Compensation Charged to
Sponsored Grants and Contracts
This memo provides
clarification of the campus policy on charging additional compensation to
sponsored grants and contracts. Charging
personnel costs to federal and many state and private grants and contacts is governed by OMB Circular A-21, which specifically
addresses faculty salary rates allowable for the academic year and periods
outside the academic year. The
Faculty must receive
prior approval by the Provost’s Office for participation in and payment of
additional compensation to ensure compliance with all conditions and
requirements of university policy, including conflict of interest, conflict of
commitment and the policies described below.
Additional compensation must be charged to federal and state grants and
contracts within 90 days of when the work was performed.
Additional
Compensation Charged to Federal and State Grants and Contracts
Federal and state
grants and contracts, including federal flow-through awards from non-federal
sources, require that compensation charged on sponsored agreements be based on
the base salary rate of the faculty member.
Base salary should not increase or decrease based upon levels of grant
funding. Therefore, charging additional
compensation on federal and state grants and contracts is prohibited for
nine-month faculty during the academic year and for twelve-month faculty,
including deans and department heads on twelve-month appointments, throughout
the entire calendar year. Exceptions can
be made for instances of inter-departmental consultation provided such
consultation is specifically provided for in the grant or approved by the
sponsoring agency.
Nine-month faculty may charge additional compensation to federal and
state grants during the summer at rates consistent with monthly base academic
year salary. Total additional
compensation charged during the summer to federal and state grants and contracts
must be equal to the percentage of total effort dedicated to the grant
multiplied by the base salary rate during the time period earned. Total additional compensation charged to
federal and state sources can not exceed 33% of base academic year salary during
the summer period. Note that NSF limits
summer additional compensation to 2/9ths of academic year base salary and NIH
salary cap limits http://grants.nih.gov/grants/policy/salcap_summary.htm
apply to the amounts that can be charged to federal grants and contracts.
Additional
Compensation Charged to Private Grants and Contracts
Nine-month and
twelve-month faculty are permitted to earn and charge private grants and
contracts at rates negotiated with the sponsor throughout both the academic
year and summer period. The negotiated
rates must be specifically provided for in the grant or approved in writing by
the sponsoring agency. Additional
compensation may not be charged to private grants and contracts during the same
pay periods that effort is committed to federal or state grants or contracts.
Additional
Compensation exceeding 33% of total base salary in a calendar year
The total of all
additional compensation earned by a faculty member from all sources during a
calendar year may exceed 33% of base salary if it complies with all provisions
above and is approved by the Provost and Chancellor.
Cc: Joyce Hatch, Vice Chancellor for A&F
Susan Pearson, Associate Provost Faculty Relations and Budget