BIO MED RESEARCH ADMINISTRATION APRIL 13, :30 SF HALL ROOM 250 SUMMER EFFORT

Overview  Policies  Institutional Base Salary  Commitments  Planning Effort  Charging Summer Salary  NIH Salary Cap  Certifying Effort

Governing Policies  Division of Biology & Medicine  Summer Guidance  University  Faculty Charges on Grants (IBS/Provost)  Controller Guidelines to Support Faculty Research Guidelines to Support Faculty Research  Funding Agency  Terms and Conditions – Executive Level 1  OMB Circular A-21: Cost Principles for Educational Institutions  Section J.10.d (1-2) – Salary rates for faculty/Periods outside the academic year

What is Institutional Base Salary?  Provost IBS Memo ( August, 2010 )  AY salary (10 mos) +  Administrative Supplement or Stipend (10/12ths) Department Chair Center Director Program Director

Institutional Base Calculation  Annual IBS Calculation  10 month AY salary + 10/12ths administrative supplement Example:  $100,000 AY salary and $5,000 Chair supplement  IBS = $100,000 + $4,167 = $104,167 (AY salary) + (10/12 th * $5,000)

Institutional Base Salary & Effort  AY Base may be supplemented for extra duties (= Effort) Any added obligation will increase the IBS  Example: Prof Smith takes on duties of interim chair and receives $6,000 supplement. What is her 10 mo. AY Base Salary (IBS)? Over what period? AY Base = $100,000 (AY) + 5,000 (AY) = $105,000 10/12 th of $6,000 supplement is added to AY Base = $5,000 2/12 th of 6,000 summer supplement = $1,000 Total Salary = $105,000 over 12 months  IBS determines amount earned in Summer and chargeable to grants Summer Salary = 20% Base = $21,000 Example: Prof Smith’s AY Base is $105,000 SS = $20,000 (100,000 x.20) – maximum chargeable to grants SS= $1,000 (5,000 x.20) – summer supplement for admin duties

AY Responsibilities  Academic Activities included in Base:  Instruction – teaching and training  Organized Research – external and internal research and training  Service– health and public service programs  Administration – Chair duties, institutional committees (IRB, IACUC, ad hoc, etc.)

More AY Responsibilities  Academic Activities Not Included in Base:  Teaching Overload  Service not part of regular/ongoing workload Excess of normal for the individual  Consulting Activities (1 day/wk or 20%) Intra University consulting is obligation with no expectation of additional compensation

Allowed Effort  Tenure-track Faculty cannot devote 100% of time to sponsored activities  Excluded Activities: Instruction/Teaching Proposal Writing University Administrative Duties  Research faculty may be able to devote 100% effort to sponsored projects  Normally restricted to 98%

Allocable Effort to Grants  Effort devoted to the conduct of the scope of work  Writing progress reports that discuss results of the work performed  Writing renewal, continuation and/or supplemental proposals specifically related to the work being conducted under a sponsored award  Attending conferences, workshops, symposia related to the work being conducting under the sponsored award  Meetings with project and/or sponsor personnel where the purpose of the meeting is to discuss the conduct, progress and/or results of the project  Reading scientific journals and scholarly publications to stay current regarding new knowledge and developments within the field of research or area related to the work under a sponsored award

What is Summer Effort?  Summer Effort - a commitment to put forth time on particular projects during the summer, not the academic year (Spt-June)  Not allowable to charge 100% effort to grants/ contracts during the months of July and August if 100% effort is not specifically devoted to research activity  100% salary should not be charged in any one summer month  Unless the faculty member will be exclusively engaged in research on the sponsored award to which their salary is allocated  Requires Chair/Director approval

What is Summer Salary?  Summer salary (SS)- compensation paid during the summer period to faculty in excess of academic year (AY) salary  Period outside the academic year appointment  July and August for 10 month appointments  A-21 J10d(2)  No Division commitment to fund SS  External funds – grants and contracts, or  Unrestricted funds – GIP  Summer effort commitment needs to be met

What is a Commitment?  Commitment: estimated amount of effort (AY and SS) an individual will devote to a sponsored project  Accepted by the sponsor as proposed in the application  Effort (%): amount of time spent working on a project  Salary ($): compensation paid to an individual

Effort Not Allocable to Grants  Instructional activities, unless the purpose of the sponsored award is instruction  Student academic advising  University service, such as service on committees  Public service, unless the purpose of a sponsored award  Writing new grant proposals, unless writing new proposals is a requirement of the sponsored award  Serving on a sponsor’s study section and/or peer review panel  Outside consulting

Commitment Example  In July and Aug 60% Professor Bee’s effort is attributable to administrative duties and 40% attributable to a sponsored research project X duties. The proposed summer effort on project X was 50%. How do you allocate summer effort? How allocate academic effort?  Summer  60% Admin account  40% Project X  Academic  10% - remainder of the research summer committed effort will have to be distributed based on actual effort over the AY (September through June)  Multiple options base on actual effort and in communication w/ PI 10% over 10 mos = 1% 10% over 4 mos = 2.5% 10% over 6 mos = 1.67% * 10% over 1 mo = 10%

Summer Effort Process  Assess commitments with PI when award is issued  Plan both academic and summer 2 awards each with 100% summer & AY proposed. How can effort be adjusted? Example: A. R % SS and 20% AY = 33% CY B. R03 – 100% SS and 5% AY = 21% CY Multiple ways to allocate – need to discuss with PI: Option 1 – reduce summer (50/50) and increase AY on both (A= 30%/B=15%) Option 2 – reduce summer on A. to 0% and increase AY to 40% Option 3 – reduce summer on B. to 0% and increase AY to 25% Option 4 – reduce overall effort by <25% - needs Division approval Option 5 - reduce >25% - needs Division and agency approval  Once Summer effort is determined then plan Academic Year effort Only faculty with 10 month appt can earn summer salary Research Faculty ((R) in title) have 12 month appointments and are not eligible for summer salary (subcode 1061)

Reduction of Effort  Under OMB Circular A-110 Guidelines, a significant reduction of the PI or key personnel effort requires prior approval  25% or more from the level of effort approved at the time of award  The 25% effort threshold relates to individual budget periods, NOT a fiscal year or cumulative award period  If non-federal award, check sponsor guidelines for any restrictions

Summer Salary Supplement Form  Faculty complete and include all planned activities:  Research  Vacation  Administration  Other  Chair must sign approving allocation  If 100% research route to Associate Deans  Chair Forms signed by Associate Deans  Review the salary cap worksheet to ensure the distribution based upon the effort is not over the cap  Review completed Form - it is auditable

Allowed Summer Activities  One day a week consulting (i.e. 20%)  Lab activities that can be clearly associated with the grant being charged  General activities which can be clearly related to grants being charged  Work on a continuation proposal for the grant being charged

Charges Not Allowable as Summer Effort on Awards  Vacation  Work on new proposals  Travel to conferences associated with another grant or contract from the one for which time is charged  Administrative tasks  Chair  Center Director  Graduate Program Director  Other

Summer Effort - Example 1  Example 1. During the month of July Professor Sol with 10 mo. AY appointment will be conducting research on a sponsored award, and also is scheduled to teach. Question - Can Prof Sol devote 100% effort to the sponsored award? Answer - No - in this case it is not appropriate, and contrary to Brown University policy and OMB Circular A-21, to allocate 100% of the July summer salary to the sponsored award due to teaching activities

What is the NIH Salary Cap?  Mandated annually by Congress  Limits Departments of Labor, Health and Human Services, and Education to the Executive Level I annual salary rate per Public Law  Cap as of 1/1/10 is $199, month cap = $166,417 (199,700/12 mos x 10 mos) 10 month cap = $166,417 (199,700/12 mos x 10 mos) 2 month Summer cap = 33,283 (20% x 166,417) 2 month Summer cap = 33,283 (20% x 166,417) 12 month = $199,700 (No Summer Salary) 12 month = $199,700 (No Summer Salary)

Faculty Appointment & Pay  Faculty appointment type  10 or12 month  Faculty pay type  10 month/10 months  10 month/12 months  12 months/12 months (not eligible)  Faculty Supplements extra duties  Chair  Center Directors  Graduate Program Directors

How is Summer Salary Cap Applied?  Summer salary charged to an NIH award on or after 1/1/10, cannot be paid at a monthly rate that exceeds $16, or $33, (Jul and Aug)  PI annual salary $200,000 (10/10 month AY appt) Summer salary = $20,000 per month Maximum amount per month that can be charged to a NIH award is $16, at 100% FTE If PI contributes 50% per month to the award then $8, can only be charged ($16,641.67x 50%) Remaining $1, cannot be charged ($10,000- $8,320.83)

Salary Cap Example 1  PI’s base salary is $235,000, she has 10/10 appt/type and commits to and spends Summer effort: 20% time on NIH A 30% on NIH B 50% on EPA  What percentage of salary (distribution) is allowed on each award?  % of salary allowed on NIH A: (33,283 x 20%) = $6,657 = (14.1% x $47,000) (NIH Cap x Summer Salary) = Capped Salary = (14.1% x 47,000)  % of salary allowed on NIH B: (33,283 x 30%) = $9,985 = (21.1% x $47,000) (NIH Cap x Summer Salary) = Capped Salary = (14.1% x 47,000)  % of salary allowed on EPA: 47,000 x 50% = 23,500  % of summer salary either unpaid or GIP $47,000 – (6,657- 9, ,500) = 6,858/47,000 = 14.6%

Helpful Links  NIH Salary Cap  Effort Commitment Tracker  Summer Salary Provost/Handbook of Academic Administration  Summer Effort Bio Med Effort and Forms Bio Med Effort and Forms  IBS Provost Salary Memo (Aug 2010) Provost Salary Memo (Aug 2010)