224  Employee Compensation Charged to Sponsored Projects

Approved by President
Effective Date: June 5, 2017
Responsible Division: Academic Affairs
Responsible Office:  Vice Provost for Research
Responsible Officer:  Vice Provost for Research

I. Purpose

This policy establishes the basis and standards consistent with federal requirements (2 CFR 200.430 Part 200 Subpart E (2) – (4)) for the administration of University employee compensation charged to externally-funded grants, cooperative agreement, and contracts. This policy applies to federal, federal flow-through, and non-federal sponsored projects.

II. Institutional Base Salary

A.  Institutional Base Salary (IBS) is the annual compensation paid by the University for an individual's appointment, whether that individual’s time is spent on research, teaching, administration, or other activities.

B.  IBS does not include payments for secondary assignments such as Department Chair, interim appointments, or any other duties for which an administrative supplement is paid; excludes longevity, merit, performance and lump sum bonus payments, honoraria, and extra compensation such as housing allowance, tuition reimbursement, etc.; and outside employment, i.e., consulting and clinical practice.

III. Compensation Charged to Sponsored Projects

A.  IBS must be used as the basis for compensation in proposals and applications for sponsored projects. Compensation charged to sponsored projects must not exceed the proportionate share of the IBS for the period during which the faculty member worked on the award, without prior approval by the sponsor.

B.  Generally, compensation charged to the sponsored project results in release time from a commensurate proportion of the employee’s regular duties. Whether requesting salary support directly from a sponsored project or providing effort on a sponsored project in the form of mandatory or voluntary committed cost sharing, the cost of the employee effort must be based in that employee’s IBS. The portion of effort multiplied by the IBS will determine the amount to be charged to the sponsored project.

C.  Extra compensation is above and beyond the IBS. Extra compensation may not be paid from sponsored projects without prior written approval from the sponsor. Extra compensation is paid for activity that is not part of the individual's normal responsibilities and is not otherwise defined under the individual's appointment and/or his/her one hundred percent (100%) effort distribution. For part-time employees, this policy applies after the employee reaches one hundred percent (100%) of his/her annualized compensation. It is the joint responsibility of the individual and his/her immediate supervisor to ensure that the individual is fulfilling primary job responsibilities, and the activities leading to extra compensation shall in no way detract from the performance of his/her assigned responsibilities and one hundred percent (100%) effort distribution. Extra compensation paid from sponsored projects during the employee’s annual period of appointment may not exceed fifteen percent (15%) of the IBS for the performance period.

D.  Faculty with nine (9)-month appointments may earn the equivalent of thirty-three and one-third percent (33.3%) of their IBS during Summer months, and faculty with ten (10)-month appointments may earn twenty percent (20%) of their IBS during Summer months paid from sponsored projects, provided that the total income earned, including pay for Summer teaching and/or administration, does not exceed thirty-three and one-third percent (33.3%) and twenty percent (20%), respectively, of their IBS.

E.  Faculty with nine (9)- or twelve (12)-month appointments and professional staff can receive extra compensation as consultants to sponsored projects in departments other than that to which they are assigned, under the following guidelines:

1.  The consulting must be across departmental lines.

2.  The extra compensation paid is commensurate with the IBS rate of pay and the amount of additional work performed.

3.  Extra compensation for consulting is not allowed if the faculty member is also identified in the proposal or award as a project investigator or senior/key personnel.

F.  Clerical and administrative personnel salary charged to sponsored projects is not intended to be additional pay or overtime pay. The amount or percent effort identified in the proposal and worked during the period of performance will be paid directly from the sponsored project as part of the employee's base pay at no more than their regularly hourly rate. Overtime pay is not allowed on sponsored projects, without prior written approval from the sponsor.

G.  Salary increases (i.e, cost of living raises, equity adjustments, merit bonuses, promotions, etc.) for employees receiving compensation from sponsored projects must be consistent with University policy.

Forms: none.

Revisions: none.

Last Reviewed: November 2020.

References: none.