Faculty & Staff Compensation from Sponsored Projects Policy
Please note: This policy is currently under review and subject to change. Please contact the Executive Director for the Office of Research and Creative Scholarship with any questions.
In keeping with federal requirements for external funding, the College must comply with the the Office of Management and Budget (OMB) Title 2 of the Code of Federal Regulations, Part 200 (2CFR, 200): “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” Because the federal government is a primary sponsor of research and other scholarly activities at Emerson College, the cost policies of the federal government are extended to all sponsored projects, regardless of sponsor type.
I. 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 the Office of Management and Budget (OMB) Title 2 of the Code of Federal Regulations, Part 200 (2CFR, 200): “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 200.430 (h) (2) which states “Unless there is prior approval by the Federal awarding agency, charges of a faculty member’s salary to a Federal award must not exceed the proportionate share of the Institutional Base Salary for the period during which the faculty member worked on the award.”
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 “course buy-out” or “course release” of the faculty member’s time by the grant to complete the work of the project.
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 performing work on sponsored projects during their regular terms of employment with the College are generally not eligible to receive pay from grants beyond their regular compensation. In rare instances where the work meets the federal criteria (below) for intra-college consulting, requests for additional compensation must be approved by the individual’s Supervisor, the appropriate Vice President and Human Resources in consultation with the Executive Director for the Office of Research and Creative Scholarship. Consultation must:
- Be across departmental lines or involves a separate or remote operation; and
- Be in addition to faculty member’s regular responsibilities to the College; and
- Be specifically provided for in the Federal award or approved in writing by the Federal awarding agency.
Federal Policy: OMB Title 2 of the Code of Federal Regulations, Part 200 (2CFR, 200): “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” Section 200.430 (h) (2) (Compensation for Personnel Services) states: Intra-Institute of Higher Education (IHE) consulting by faculty is assumed to be undertaken as an IHE obligation requiring no compensation in addition to Institutional Base Salary (IBS). However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the faculty member is in addition to his or her regular responsibilities, any charges for such work representing additional compensation above IBS are allowable provided that such consulting arrangements are specifically provided for in the Federal award or approved in writing by the Federal awarding agency.
II. 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 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).
III. Administrative Support Salaries Charged to Sponsored Projects
Because administrative support is designated under OMB Title 2 of the Code of Federal Regulations, Part 200 (2CFR, 200): Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 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 for approval.
For more information: Eric Asetta