The time and effort percentages of project personnel should be included in the budget. Proposed salaries and wages must be in accordance with University approved rates.
Federal and state agencies, private foundations, organizations, and industry sponsors provide funding to enable the Southern Utah University to conduct research, public service, and training projects. The University's effort certification reporting system is the mechanism for certifying that the salaries and wages charged to sponsored projects reasonably reflect the level of effort proposed and allowed on the award and the levels donated to the projects. Section J.10 of OMB Circular A-21 provides the framework for acceptable methods of documenting the effort of employees on sponsored projects. As a condition to receive federal funding, institutions must maintain an accurate system for reporting the percentage of time (i.e., effort) that employees devote to federally sponsored projects. All sponsored effort must be certified regardless of source of funds. The time and effort of project personnel should be included in the budget. Proposed salaries and wages must be in accordance with University approved salary rates.
To determine total salaries and wages, list the percentage of effort to be spent by each person including technical and clerical assistants who will work directly on the project. Effort should be shown in terms of percentage of full-time effort or in person-months. For individuals paid on an academic year basis, show a breakdown between academic year and summer effort.
PI's may not budget any individual in excess of 100% of effort, including all sponsored projects, clinical, instruction and other University activities. It is important to consider each individual's other commitments to other sponsored projects since most sponsors will review an individual's total committed effort to funded and pending project support.
Generally, an employee may not receive more than his or her regular salary annualized over 12 months by engaging in sponsored projects. For example, a faculty member on a typical nine-month contract earning $90,000 ($10,000 per month) could earn up to an additional $30,000 during the fiscal year from sponsored agreement(s). If specific incremental increase figures are not available, estimate the increase at 3% per year as per NIH policy.
Salaries and wages charged to a project must reasonably represent the proportionate share of effort that directly benefits the project. It is recognized that in an academic setting, teaching, research, service, and administration are often intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Therefore, it is acceptable to rely on estimates in determining the allocable effort to be charged to a project.
If a faculty member holds a full-time, nine-month contract, the salary for that 9 month period is the base salary. Base salary does not include overload or incidental pay. During the academic year, federal funds must replace (not augment) some portion of the base salary. For example, if a faculty member proposes 20% of his/her effort to a federally-funded project, a maximum of 20% of institutional base salary may be charged to the grant, and this money must “buy out” salary, not add to it. The workload should reasonably match salary distribution as verified with an effort report. During the academic year, 9 month employees should modify the Departmental Action Form (DAF) in order to reduce the base salary in a manner consistent with the effort and salary allowed in the sponsored agreement.
For SUU faculty with a typical nine-month academic year appointment, summer salary for government grants is calculated on the basis of 1/9 of the academic year salary for each summer month devoted to the project. NIH normally allows faculty to charge up to three summer months to a grant. Where the sponsor allows it, and where a faculty member with a nine month contract elects to devote three summer months of effort to the sponsored project, the grant shall be charged 3/9 of the institutional base salary. The amount of salary requested must correspond to the amount of effort actually devoted to the project and be verified in the effort report.
Faculty is reminded that compensation for effort is treated the same way regardless of the source of funds. For example, faculty who do not accrue vacation days during the academic year when compensated from departmental salary accounts do not accrue vacation days during periods compensated using sponsor funds.
Some sponsors, like NSF, limit the amount of summer salary that may be charged to a grant. The NSF Grant Policy Manual (GPM NSF 02-151)
states: NSF policy on funding of summer salaries (known as NSF's "two-ninths rule") remains unchanged: proposal budgets submitted should not request, and NSF-approved budgets will not include, funding for an individual investigator that exceeds two-ninths of the academic year salary. This limit includes summer salary received from all NSF-funded grants.
Salary charges to government grants and contracts are allowable at the approved base salary rate. Extra compensation from a sponsored project over and above the base rate is not allowed except in unusual cases where the consultation is across departmental lines or involves a separate remote operation and the work performed is in addition to the regular departmental load.
The policy of SUU is to allow employees receiving salary from sponsored agreements to receive additional incidental compensation from other institutional resources with the approval of the dean and provost. Employees should keep in mind that federally supported faculty earning additional remuneration from institutional resources must be able to document that their percentage of effort committed to the sponsored project remains substantially the same.
University Policy on Supplemental and Overload Compensation
Faculty may receive extra-service pay as consultants for federal and federal flow-through projects in other departments under the following guidelines:
For example, a contract to conduct a social science survey requires three hours of statistician work to fulfill the report requirements. A faculty member in the Statistics department may receive extra-service pay from the grant or contract assuming the abovementioned requirements are met and the consulting time does not interfere with the statistician's primary job responsibilities.
Note: The effort certification requirements do not apply to outside consulting income earned outside the University.
Overtime charges on sponsored agreements are normally unallowable for exempt employees. Overtime for nonexempt employees may be charged only under the following circumstances:
Overtime must be pro-rated to each account from which an employee is paid unless the overtime is clearly and demonstrably necessitated by demands placed on that employee on behalf of a specific project.
Compensation for part-time faculty shall be charged at a rate not in excess of that regularly paid for the part-time appointment. Substantial changes in work assignments should, as a matter of course, prompt the appropriate dean and the employee to review the job description and base salary.
Generally, an employee may not receive more than his or her regular annualized salary by engaging in sponsored projects. All employees will have an approved maximum total compensation set by the University, which shall constitute that person's institutional base salary.
