Summer Salaries on Sponsored Research Grants

1. Summer Salaries on Sponsored Research Grants Clyde Briant and Regina White April 17, 2008

2. Circular A-21 • When Brown accepts a federal grant, it is with the condition that the University will comply with Circular A-21 of the Office of Management and Budget. • Brown must demonstrate to the federal government that we have systems adequate to insure compliance.

3. Some Background Points • A-21 is not new • A-21 makes a clear distinction between summer salary and academic year salary • Summer salary is not back pay for work done during the academic year

4. From UC Berkeley NSF Audit • Sampled 30 PIs • Found • Improperly charged employee work activities not directly benefiting NSF grants • Employees did not have suitable means of verification documenting that the work effort charged was actually performed

5. From UC Berkeley NSF Audit • 12% of NSF salary charges were not supported by adequate documentation • UCB inappropriately charged 2% ($15,543) for employee activities not directly benefiting the sponsored project The systemic nature of these control weaknesses raises concerns about the reasonableness and allowability of the remaining $25M in FY2006 labor costs UCB charged to NSF grants and the labor portion of the University’s $221M of other Federal Awards http://www.nsf.gov/oig/index.jsp

6. Sponsored Research • Sponsored research means all research and development activities sponsored by federal and non-federal agencies and organizations. • The accounting system reporting charges will reasonably reflect only the activity for which the employee is compensated by the institution. Practices vary among institutions and within institutions as to the activity constituting a full workload. Hence, the system will reflect categories of activities expressed as a percentage distribution of total Brown activities.

7. Compensation for Personal Services • Personal services include salaries, wages, and benefits • Charges to sponsored agreements can include reasonable amounts of activities contributing and intimately related to work under the agreements such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences.

8. More About Compensation and Activity • Sponsored research can include training of individuals in research techniques where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instructional function. • It is recognized that in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible or expected. Reliance is placed on estimates in which a degree of tolerance is expected.

9. Charges Not Allowable to Summer Salary on Contracts and Grants • Vacation • Work on new proposals • Travel to conferences associated with another grant or contract from the one for which time is charged • Administrative tasks

10. Some of the Allowed Activities • One day a week consulting • 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. If effort is charged to a grant, then the activities performed must benefit that grant. The effort allocation must be consistent and explainable.