Campus Research Administers Meeting 05/16/17

Agenda Rcc updates Effort – NSF and the 2 ninths rule Closeout Implementation team update OSP updates

Effort review Julie cole, Michelle Rigsbee and Keith Hurka-owen Drafting report You folks rock Recommendations on the way Two glaring omissions (and they are my fault) Changes in NSF 2-ninths policy Cost sharing your way to compliance

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) The NSF has historically restricted total salary compensation to two months in a specific annual period. This restriction has been modified but requires additional justification in proposal budgets and/or other documentation. Duke defines the annual period as the Duke fiscal year – July 1 – June 30.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) (a) Senior Personnel Salaries & Wages Policy NSF regards research as one of the normal functions of faculty members at institutions of higher education. Compensation for time normally spent on research within the term of appointment is deemed to be included within the faculty member’s regular organizational salary. As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E, including 2 CFR § 200.430(i). If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget.17 Under normal rebudgeting authority, as described in Chapters VII and X, a recipient can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long as that change would not cause the objectives or scope of the project to change. NSF prior approval is necessary if the objectives or scope of the project change.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) NSF regards research as one of the normal functions of faculty members at institutions of higher education. Compensation for time normally spent on research within the term of appointment is deemed to be included within the faculty member’s regular organizational salary.

University Effort

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) Under normal rebudgeting authority…a recipient can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) No prior approval from NSF is necessary as long as that change would not cause the objectives or scope of the project to change. NSF prior approval is necessary if the objectives or scope of the project change

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) Faculty should carefully consider the amount of effort required to successfully address the research aspects of the proposed project and budget accordingly. Requests for salary in excess of the NSF 2 months’ rule should be justified and documented in the proposal budget and justification. Award approval from NSF when this information has been included in the proposal package constitutes agency approval. NSF policy also allows rebudgeting to exceed two months of support. Must follow Duke internal rebudgeting process.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) Duke Policy review: A maximum of 75% effort per month spread over all four summer months (July, August, May and June) is allowed for those supported with federal funding Salary request for greater than 75% of one summer month on a federal grant requires the Management Center’s approval through the Vice Provost for Research The maximum amount of federally funded effort for which faculty may be compensated during the summer is 2.5 months The remaining 0.5 month can be taken from institutional funds or other non-federal sources The 0.5 month effort can be “banked” during the academic year and paid out through the summer supplements from institutional funds.

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) Duke Policy review: Possible exceptions Amboseli baboon research project (kenya) Susan Alberts

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) Duke Policy review: Possible exceptions Monitoring Forest elephants (Gabon) John Poulsen

NSF: (i) Salaries and Wages (Lines A and B on the Proposal Budget) Duke Policy review: Possible exceptions Comparative studies of hyenas and lemurs (Namibia) Christina drea

Voluntary Committed cost sharing Duke Policy: Include cost sharing only when required by the FOA. VPR waiver to include VCCS if not required. Impacts the denominator in F&A Cost Proposal. The NSF prohibition on voluntary committed cost sharing applies to proposal submissions. Failing to meet our effort commitments is the greater risk to the University.

Current and Pending Case study no. 1 NSF grant A – 1 committed summer Month Nsf grant b – 1 Committed summer month Nsf Proposal – 1 committed summer month NSF is awarding proposal #1. Now what?

Current and Pending Case study no. 2 NSF grant A – 1 committed summer Month Nsf grant b – 1 Committed summer month Nsf Proposal – 2 committed summer month NSF is awarding proposal #2. Now what?

Post award effort management Case study no. 3 Your PI has committed 2 months on an active NSF grant. She wants to pick up an extra graduate student and she knows that NSF recognizes that a portion of her academic salary covers her research effort. She asks that you rebudget all of her salary support into graduate student funding effectively dropping her effort to zero in the Duke systems. Now what?