NCURA FRA XIVMaking Connections Creating Harmony

Extra Compensation Versus

Direct Cost Versus

Administrative Cost

1

What we know or need to know

Must follow your institution policies How your institution defines

Institutional Base Salary (IBS) Full-time Equivalent Appointment (FTE) Summary Pay – (outside academic year

for 9 month faculty) Additional or Supplemental Pay When can you charge Admin and Clerical

2

Guidance

A-21 J.10 Compensation for personal services

Must follow institutional policy consistently applied across all fund sources

Effort must be certified, be reasonable, contribute and intimately related to the work

Charges allowable at base salary rate Intra university consulting is not usually

compensated Additional Pay must have prior approval

3

Guidance

A-21 D.1. Direct Costs D.2. Application to sponsored agreements E.1. F&A Costs F.6. Departmental Admin Expenses

F.6.b.(1) Costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs

F.6.b.(2) The salaries of administrative and clerical staff should normally be treated as F&A Costs

Exhibit C Examples of Major Project

4

Guidance in Proposed OMB Uniform Guidance

Subtitle III Direct and Indirect (F&A ) Costs .615 Direct Costs

(a) identified specifically, directly assigned relatively easily with high degree of accuracy… and costs incurred for the same purpose in like circumstances treated consistently

(d) The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate where all of the following conditions are met:

(1) administrative or clerical services are integral to a project or activity;

(2) individuals involved can be specifically identified with the project or activity;

(3) such costs are explicitly included in the budget; and (4) the costs are not also recovered as indirect costs.

It will be interesting once audits start to determine actual interpretation

5

Guidance

A-110 C. 25 Revision of budget and program plans Prior Approval

Change in key person Absence for more than three months or a 25%

reduction in time devoted to project of project director or principal investigator

Debarment and Suspension

6

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Agency NSF

2/9ths salary max per year

DHHS Salary Cap

Most agencies under DHHS Prior to 12/23/11 NIH, AHRQ and SAMSA After 12/23/11 Includes ALL HHS awards

8

To Whom are they Generally Applicable

Faculty / Principal Investigator Summer Pay – At base salary rate Additional Pay/Supplemental Pay

Prior Approval Required What is your institutional policy What is the rate of pay

Intra university consulting Sabbatical leave costs

Institutional Policy Bonus Payments – Rarely allowed for faculty

on sponsored awards

9

To Whom are they Generally Applicable

Administrative, Departmental, Hourly Staff, Fellows or Trainees Direct or F&A Costs

Admin and Clerical – Unique job description can help define unlike circumstances

Overtime Pay Supplementation of Trainee’s Stipend on NIH

fellowship or training grant Bonus Pay – If allowed under institutional

policy

10

Institutional Policy

Institutional Base Salary Compensation Additional Pay Supplemental Compensation Intra university consulting Salary Rates Direct Costs Administrative and Clerical Costs Institutional Base Salary (IBS) Appointments (FTE, 9 month, 12 month) Summer salary

11

Presenters

Evan Crierie

Assistant Director, Office of Research Administration, University of Maryland, College Park

Tim Reuter

Director Post Award Operations, Stanford University