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SUMMER EFFORT. BIO MED RESEARCH ADMINISTRATION APRIL 13, 2011 9-10:30 SF HALL ROOM 250. Overview. Policies Institutional Base Salary Commitments Planning Effort Charging Summer Salary NIH Salary Cap Certifying Effort. Governing Policies. Division of Biology & Medicine
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SUMMER EFFORT BIO MED RESEARCH ADMINISTRATION APRIL 13, 2011 9-10:30 SF HALL ROOM 250
Overview • Policies • Institutional Base Salary • Commitments • Planning Effort • Charging Summer Salary • NIH Salary Cap • Certifying Effort
Governing Policies • Division of Biology & Medicine • Summer Guidance http://biomed.brown.edu/bmra/download/SummerSalaryCombined.pdf • University • Faculty Charges on Grants (IBS/Provost) http://biomed.brown.edu/bmra/pp • ControllerGuidelines 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) + (10/12th * $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 • 10/12th of $6,000 supplement is added to AY Base = $5,000 • 2/12th 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. R01- 100% 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 111-117 • Cap as of 1/1/10 is $199,700 • 10 month cap = $166,417 (199,700/12 mos x 10 mos) • 2 month Summer cap = 33,283 (20% x 166,417) • 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 $16,641.67 or $33,283.33 (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 $16,641.67 at 100% FTE • If PI contributes 50% per month to the award then $8,320.83 can only be charged ($16,641.67x 50%) • Remaining $1,679.17 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- 9,985- 23,500) = 6,858/47,000 = 14.6%
Helpful Links • NIH Salary Cap http://grants.nih.gov/grants/policy/salcap_summary.htm • Effort Commitment Tracker http://biomed.brown.edu/bmra/tools • Summer Salary Provost/Handbook of Academic Administration • Summer Effort Bio Med Effort and Forms • IBSProvost Salary Memo (Aug 2010)