NCURA FRA XIV Making Connections Creating Harmony

1. NCURA FRA XIVMaking Connections Creating Harmony Extra Compensation Versus Direct Cost Versus Administrative Cost

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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