|History:||Issued||-- July 31, 2015|
|Last Reviewed --|
|Related Policies:||Cost Sharing Policy; Faculty Handbook; Post-Award Principal Investigator Handbook; Reporting Financial Irregularities Policy; Sponsored Award Costing Policy|
|Additional References:||Sponsored Accounting Office|
|Responsible Official:||Director, Sponsored Accounting tel. (202) 319-6402|
I. Policy Statement
The University expects a faculty member to devote full-time service to research, teaching, and University service during the academic year. In return, a faculty member is paid a base salary for 100 percent effort in performing his or her faculty responsibilities. Compensation that a faculty member receives from a Sponsored Award (defined below) is governed by regulations set forth in applicable federal Office of Management and Budget (OMB) requirements¹. This policy sets forth the requirements for determining the compensation that is charged to a Sponsored Award, and for faculty members' completion of effort certification reports. This policy applies to all Sponsored Awards regardless of funding source (i.e. federal versus non-federal) or type (research, training, contract for services, etc.).
A. Base Salary means the pay that a faculty member receives during the academic year (fall/spring terms) in return for performing faculty responsibilities in accordance with the Faculty Handbook.
B. Research Base Salary means the sum of a faculty member's base salary and any stipend(s). The Research Base Salary is used to calculate the salary that can be charged to a sponsored research award.
C. Sponsored Award means a grant, contract or other method of funding provided to the University by an external entity (such as the federal government or a private foundation or company) and for which there are actual or implied conditions or expectations that the University must meet. Such conditions and expectations often include, but are not limited to: • sponsor control of the scope of the project; • technical, financial, or progress reporting; • a cost sharing component; • recoveries for facilities and administrative (i.e. indirect) costs; and/or • re-granting or subcontracting of some of the funds to other entities. Sponsored Awards often involve activities such as research, teaching/training, or the provision of services by University personnel to other entities.
D. Stipend means a payment a faculty member may receive from a supplementary appointment, such serving as department chair. A stipend is paid in addition to the base salary.
III. Compensation from Sponsored Awards
A. Faculty Members A faculty member may conduct the work for a Sponsored Award during the academic year only, during the summer only, or during both periods. The faculty member can identify in the proposal which time periods when he/she will receive salary from the award. The percentage of time that a faculty member spends on a Sponsored Award during the academic year is either: a. charged as salary to the award in the same proportion as the percentage of time spent; b. counted as cost sharing by the University if no salary is charged to the award during that time; or c. a combination of a. and b. During the academic year a faculty member cannot receive additional salary from a Sponsored Award over and above his or her research base salary. All salary charged to an award during the academic year replaces the corresponding amount that would be paid to the faculty member from the University's operating budget. A faculty member may devote up to 100% effort on a sponsored award during the summer months, and thus charge his or her time to the sponsor in accord with the effort, subject to any limitations imposed by the sponsoring entity. On all proposals submitted to a sponsor, a faculty member must indicate the percentage of effort that he or she intends to devote to the work required for the award during the academic year and/or during the summer. The percentage(s) indicated will determine the proportion of the faculty member's salary that can be charged to the sponsor of the award during the academic year and the additional salary that the faculty member can receive from the award during the summer.
B. Administrative Personnel Direct charging of administrative salaries to federal awards may be permissible if: • Administrative or clerical services are integral to a project or activity; • Individuals involved can be specifically identified with the project or activity; • Such costs are explicitly included in the budget or have the prior written approval of the awarding agency; and • The costs are not also recoverable as indirect costs. If uncertain whether administrative or clerical salaries may be directly charged to a federal award, contact the Sponsored Accounting Office.
IV. Effort Reporting Anyone who receives salary funding from Sponsored Awards will be required to certify the percentage of effort spent on each award on a biannual basis. The University has implemented the following effort certification process: • Each individual's salary distribution is established on an Appointment Form or Employee Data Form (EDF), as applicable. • During the effort certification period the salary distribution for the individuals working on the award must be monitored by the Principal Investigator (PI) on an on-going basis and adjusted for changes in actual activity. • Subsequent to the effort certification period, each individual who has charged wages to an award will receive a biannual effort certification report. On the effort certification report the individual must confirm or change the percentage of total time spent on each award so that the payroll distribution reflects the actual work performed. • The PI is responsible for certifying all effort expended on his/her sponsored award by approving all effort certification forms for that award. Certification cannot be delegated. The effort certification report for the PI also must be approved by his/her supervisor. The effort certification report will be distributed to the PI twice annually and requires the PI's response in accordance with the foregoing process. PIs who do not respond to the certification reporting request in a timely manner will be reported to their Dean and then the Provost. If the effort certifications are not submitted by the required deadlines, the Sponsored Accounting Office will cease processing any expense paperwork until the effort certifications are received and complete. ¹ For awards effective December 26, 2014, following OMB Uniform Guidance (2 CFR §200). For awards effective before December 26, 2014, follow OMB Circular A-21, Cost Principles for Educational Institutions (2 CFR §220) and/or OMB Circular A-110 (2 CFR § 215).