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Research Administration: Salary Cap Management March 2014 Tricia L. Zeh , MS, CRA, CCRP Candice Weber, MA, CRA

Research Administration: Salary Cap Management March 2014 Tricia L. Zeh , MS, CRA, CCRP Candice Weber, MA, CRA Director of Research Administration Senior Research Administrator Office of the Dean Office of the Dean.

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Research Administration: Salary Cap Management March 2014 Tricia L. Zeh , MS, CRA, CCRP Candice Weber, MA, CRA

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  1. Research Administration: Salary Cap Management March 2014 Tricia L. Zeh, MS, CRA, CCRP Candice Weber, MA, CRA Director of Research Administration Senior Research Administrator Office of the Dean Office of the Dean

  2. This is the easy part. The challenge will be working with my administrator to make sure the effort reporting and expense allocations keep us compliant….

  3. Objective Examine best practices for compliant management of the “NIH” Salary Cap on Federal awards. • What is the cap and when does it apply? • How do I calculate the amount to be cost shared? • Establishing cost share accounts & charging salary • Monitoring cost share and Effort Reporting • Using the RA Dashboard

  4. What is the Cap? When does it apply? • Effective 1/12/14 the NIH salary cap increased from $179,700 to $181,500 • This is due to an OMB approved increase to Executive Level II of the federal pay scale • NOTE: NIH is not the only DHHS agency to utilize the Executive Level II salary cap limitation • Public Law 112-10 extends the salary limitation to most other DHHS agencies. • Such as: CDC, FDA, CMS, HRSA, AHRQ, SAMHSA • Review program guidance carefully at proposal stage

  5. Applying the Salary Cap: VCU Faculty • All Faculty who have total Institutional Base Salary (IBS) over the salary cap in effect at the time of proposal and/or award must cost share the portion of their salary that is over the cap in proportion to the effort committed to the project. • Applies to all personnel over the cap, regardless of whether they are designated as key personnel • IBS is the total of VCU and MCVP contracted salary • VA appointments (1/8ths) are not part of VCU’s IBS

  6. Calculating the Amount for Cost Share Best Practice: Use NIH Salary Cap Calculator • Link to SOM website: NIH Salary Cap Calculator • This calculator provides: • The annual salary to be charged to the sponsor • The annual salary to be cost shared • Consideration of whether the faculty member has MCVP compensation • The percentage to charge to the VCU PAF per pay period for both sponsored and cost share indexes

  7. Calculating the Amount for Cost Share • Theannual salary to charge the Federal sponsor is a direct calculation of: • [Current Cap]*[Committed Effort] • The annual salary to be cost shared is equal to: • [IBS – Current Cap]*[Committed Effort] • Example: IBS = 225,000 / Cap = 181,500 / Effort = 30% • Federal Share = [Current Cap]*[Committed Effort] • 181,500 * 30% = 54,540 • Cost Share = [IBS -Current Cap]*[Committed Effort] • [225,000 – 181,500] * 30% = 13,050

  8. Award Set-Up:Establishing Cost Share Accounts Best Practice: At the time of award, department administrators verify all needed accounts are established & linked accurately: • Request from G&C a cost share account(s) be established at the same time as the grant accounts. • Verify the cost share account is set-up appropriately with the responsible department and linked to the appropriate Banner GrantID(use Banner screens FTIORGH and FTIFATA)

  9. Award Set-Up:Charging Cost Share • Use the NIH Salary Cap Calculator • The percentage to charge to the VCU PAF per pay period will be calculated for you for both the federal share and the cost share amount. • If an investigator has an MCVP salary component the total percent charged to the VCU PAF (sum of federal and cost share) WILL NOT match the sponsor committed effort. (MCVP salary is not part of VCU payroll) • Effort Reporting accounts for MCVP compensation, so project computed effort according to payroll will reflect accurately in that system.

  10. Award Set-Up:Charging Cost Share • Example: IBS = 225,000 / Cap = 181,500 / Effort = 30% • Federal Share = [Current Cap]*[Committed Effort] • 181,500 * 30% = 54,540 • Cost Share = [IBS - Current Cap]*[Committed Effort] • [225,000 – 181,500] * 30% = 13,050 • If VCU Salary Only – Divide amounts to be charged by # of pay periods (24 for a budget year)

  11. Award Set-Up:Charging Cost Share • Example: IBS = 225,000 / Cap = 181,500 / Effort = 30% • If there are VCU and MCVP salary components, the breakdown must be known, and additional calculations are needed • IBS = VCU + MCVP • 225,000 = 150,000 + 75,000 Note the Denominator is on the VCU portion of salary paid through VCU payroll.

  12. On-going Management of Cost Share: Monitoring through-out the Award Best Practice: In addition to monthly monitoring of accounts, cost share allocations to VCU payroll should be reviewed anytime: • A new budget period begins • Salary Cap changes (currently Executive Level II) • Total IBS changes (a raise or decrease) • Distribution between MCVP/VCU salary changes (shift in salary between entities)

  13. On-going Management of Cost Share: Effort Reporting When personnel certify their effort they are certifying total project effort performed during the given effort reporting time period. How that effort is funded (sponsored vs. cost shared) happens based on labor distribution allocations within our payroll system. • Computed Effort in the ECRT system provides an effort estimate based on payroll allocations. • This computation includes both sponsor paid salary and cost share salary associated with the project.

  14. On-going Management of Cost Share: Effort Reporting To ensure effort reporting Computed Effort is as accurate as possible administrators must: • Make sure cost share accounts are linked to the proper sponsored project. • This ensures that payroll charged to the sponsor and the cost share account is summed to reach a total Computed Effort. But ensuring correct effort does not stop there! • Investigators will certify their total effort on a project. • Administrators must make sure the distribution of salary for how that effort is funded is in compliance with the cap. If the distribution is wrong and we charge the Federal grant salary above the cap we are out of compliance.

  15. On-going Management of Cost Share: Effort Reporting Example: IBS = 225,000 / Cap = 181,500 / Effort = 30% • Federal Share = [Current Cap]*[Committed Effort] • 181,500 * 30% = 54,540 • Cost Share = [IBS - Current Cap]*[Committed Effort] • [225,000 – 181,500] * 30% = 13,050 **Total Computed Effort will look the same even if the distribution between the sponsor and cost share salary support is incorrect!

  16. On-going Management of Cost Share: Effort Reporting • Certified Effort total is entered into one box. • Investigators certify the total effort performed on the project. • Administrators must ensure the payroll distributions are correct so that we are in compliance with the salary cap. • Best Practice – review project staff effort allocation on a monthly basis with PIs as part of the project reconciliation to confirm accuracy of current staffing or make payroll changes if necessary to align with effort performed.

  17. Best Practice: Use the RA Dashboard to aid in effective management of cost share accounts and commitments.

  18. Using the RA Dashboard: Management of Cost Share Commitments Identifying which awards have cost share commitments on record (either Voluntary or Mandatory)

  19. Using the RA Dashboard: Management of Cost Share Commitments Cost share commitments are recorded in InfoEd at the time of award – contact OSP if this information is not correct or needs to be updated

  20. Using the RA Dashboard: Management of Cost Share Commitments Identifying awards that have a cost share commitment, but no associated cost share index

  21. Using the RA Dashboard: Management of Cost Share Commitments Reasons why there may be no associated cost share index… • A cost share index was not generated by G&C or requested by the department at award set up -> Complete the cost share authorization form and submit to G&C Accountant • A cost share index was set up, but the award is in a new competitive cycle with a new Grant ID - > Complete the cost share authorization form and submit to G&C Accountant: be sure to request that the index be associated with the most recent Grant ID • Department is cost sharing using as an index that is not currently associated with the award’s Grant ID - > Request that G&C associate the cost share index with the award

  22. Using the RA Dashboard: Management of Cost Share Commitments The Banner screen FTIFATA will tell you what award a cost share index is associated with: * The initial or Year 1 grant index will be shown, but this cost share is associated by default with all grant indexes under the same Grant ID

  23. Using the RA Dashboard: Management of Cost Share Commitments NIH Over-the-Cap Salary portletfocuses on VCU’s commitment to cost share the portion of an individual’s salary that is above the cap of $181,500

  24. Using the RA Dashboard: Management of Cost Share Commitments Find the commitment on record on the “Personnel” screen of InfoEd PT: Total effort commitment recorded in InfoEd

  25. Using the RA Dashboard: Management of Cost Share Commitments Actual % VCU salary from individual’s PAF in Banner Federal = amount VCU salary charged to grant index, Cost Share = amount VCU salary charged to associated cost share index

  26. Using the RA Dashboard: Management of Cost Share Commitments Expected* labor distribution on VCU PAF - uses same calculation as NIH Salary Cap Calculator spreadsheet. *Note: Expected labor distribution is assuming payroll will be charged according to commitment on record. If actual effort to be charged differs, use NIH Salary Cap Calculator to verify.

  27. Best Practices Highlighted • Use the NIH Salary Cap Calculator to determine total and per pay period allocations to sponsored vs cost share accounts. • At the time of award, department administrators verify all needed accounts are established & linked accurately • Review project staff effort allocation on a monthly basis with PIs as part of the project reconciliation to confirm accuracy of current project staffing or make payroll changes if necessary to align with effort performed. • In addition to monthly monitoring of accounts, cost share allocations on VCU payroll should be reviewed anytime changes occur that could effect labor distribution percentages. • Use the RA Dashboard to aid in effective management of cost share accounts and commitments.

  28. Questions? • Relevant Links: • Award Management- NIH Salary Cap and Cost Share • Allocation & Monitoring of Effort on Sponsored Projects • NIH Salary Cap Calculator • SOM Research Dashboard web resources Email: SOMRESADMIN@vcu.edu

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