In keeping with federal requirements for external funding, the college must comply with the Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions for all federally sponsored programs. Because the federal government is a primary sponsor of research and other scholarly activities at Saint Anselm College, the cost policies of the federal government are extended to all sponsored projects, regardless of sponsor type.
Faculty Compensation from Sponsored Projects: Academic Year Effort
Faculty may not receive more than their regular annual salary as a result of participation in sponsored projects during the academic year. This is in accordance with OMB Circular A-21 Section J.10.d.(1) which states "In no event will charges to sponsored agreements, irrespective of the basis of computation, exceed the proportionate share of the base salary for that period."
Some sponsors will reimburse the college for a portion of a faculty member's academic year salary when the sponsored project is carried out during the academic year. This does not increase the faculty member's salary, but generally helps the institution recover a portion of the salary expenses that are allocable to the sponsored project. This is commonly referred to as a "buy-out" of the faculty member's time by the grant (or can take the form of a "course buy out") to complete the work of the project. Salary replacement funds provided by grants shall be returned to the College's general fund.
Example: A faculty member's annual 9-month salary equals $50,000. As a PI on a grant, the faculty member requests and is granted $5,000 from the sponsor in academic year salary to cover 10% effort spent on the project during the academic year. The faculty member would still receive a salary of $50,000 for the academic year, not $55,000.
Faculty Compensation from Sponsored Projects: Summer Effort
A faculty member on a 9-month contract may be paid summer salary (supplemental pay over and above the 9-month academic year salary) for effort contributed to a sponsored project during the 3-month summer period. Charges are based on the same monthly base rate of pay as during the academic year. Summer salary chargeable to grants and contracts is limited to that effort actually expended on the project. Faculty members receiving three months of summer support (maximum allowable) from a sponsored project must put the entire three summer months into the work of the grant. Summer salary cannot be paid for effort expended during the academic year.
Example 1: A faculty member on a 9-month contract may be paid one-ninth of his/her prior academic year salary for one summer month of sponsored research. If the faculty member's academic year salary is $50,000 for nine months, the faculty member receives an additional $5,556 ($50,000 / 9 = $5556) for the month spent working on the sponsored research project. $50,000 + $5556 = $55,556 in total pay.
Example 2: A faculty member plans to spend two weeks at ½ effort (one week total effort) in the summer prepping for a grant funded project (e.g., a program he or she will lead). Delivery of the program itself will constitute one additional week of full-time effort. Thus, the faculty member may receive supplemental pay from the grant equivalent to 2 weeks in total (1/2 month). Assuming the faculty member's salary is $50,000 for nine months, the faculty member receives an additional $2,778 ($50,000 / 9 = $5,556 monthly salary divided by 2 to get to ½ month effort).
Compensation from Sponsored Projects: 12-Month Faculty, Administrators, and Staff
All 12-month employees performing work on sponsored projects are generally not eligible to receive pay beyond their regular compensation. In rare instances where the work meets the federal criteria for intra-college consulting (work must be clearly distinct from their normal duties and occur outside of their normal work hours or during a period for which the individual has used accrued leave) during the period for which they request supplemental pay. Requests must be approved by the individual's Supervisor, the appropriate Vice President and Human Resources in consultation with Sponsored Programs and Research.
Federal Policy: OMB Circular A-21 J.10.d (1) (Cost Principles of Educational Institutions - Compensation for Personnel Services) states: Since intra-university consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full-time base salary, the principle also applies to faculty members who function as consultants or otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution. In unusual cases where consulting is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his/her regular departmental load, any charges for such work representing additional compensation above the institutional base salary are allowable provided that such consulting arrangements are specifically provided for in the agreement or provided in writing by the sponsoring agency. An employee providing consulting services within their primary department is ineligible for additional compensation (OMB Circular A-21). An employee who is an investigator on a sponsored project cannot be compensated for intra-university consulting on that project.
Administrative Support Costs Charged to Sponsored Projects
Because administrative support is designated under OMB Circular A-21 as being part of our indirect costs, administrative support salaries should not be directly charged to federal grants (supplemental or otherwise). PIs with extraordinary administrative support needs in connection with a grant should speak with the Dean or the appropriate Vice President prior to proposal submission about utilizing some of the indirect dollars returned to the school under the college's Indirect Cost Distribution Policy to assist with these needs.