Allocation of a faculty member’s time and salary is often complex and depends upon the various activities in which the faculty member is engaged. Faculty whose salary is supported on sponsored projects must follow the requirements set forth by the federal government in the Office of Management and Budget Circular A-21 and Rivier’s implementation of those requirements. This document provides guidance for faculty and administrators in complying with the requirements outlined by Rivier and Circular A-21.
Faculty may have several professional assignments in fulfilling their responsibilities to the University. Teaching, research, clinical activities, professional development and institutional service are common activities for Rivier faculty. In general, the source of funding of salary for these activities should be consistent with the effort in each area. In addition, all of the effort that an individual provides in his/her capacity as a faculty member must be part of the time that the University supports. There can be no part of a faculty member’s job responsibilities that is not funded, i.e., no volunteer responsibilities that relate to current or future Rivier responsibilities. When a portion of a faculty member’s salary is funded through federally sponsored projects, it is essential that there be another source of salary support for activities that are not allowable or allocatable directly to sponsored projects under OMB Circular A-21.
When faculty have significant teaching, patient care or institutional assignments while they are working on sponsored projects, Rivier expects that there will be multiple sources of salary support that reflect effort in those activities. Generally, institutional funds are used to support teaching, professional development and institutional service. To the extent possible, sponsored funding should support faculty work on research and demonstration projects although there are instances when institutional funds support research.
In some cases, faculty effort and salary support can be attributed predominately to sponsored projects. Even in those circumstances, most faculty should not derive more than 95% of salary support from sponsored sources during the course of a year. There may be special circumstances where an individual has been released from teaching and clinical commitments and has been relieved of all institutional assignments to spend 100% time on his/her federally sponsored projects. In these cases it may be appropriate to derive 100% support from sponsored sources.
In order to be certain that the University adheres to OMB Circular A-21 Guidelines, Rivier will take additional steps to monitor faculty effort and sources of support for salary when an individual derives more than 80% of salary from sponsored activities during any one academic quarter. For these individuals, additional review will be conducted by the Finance Office, which will consult with the Vice President for Academic Affairs to review effort and salary support. Particular attention will be applied to assure that significant institutional responsibilities including committee assignments, student mentoring outside of the laboratory or research site (beyond “student augmentation”) and administrative responsibilities are not funded by federally sponsored activities. In addition, time spent preparing new grant applications, including data gathering in research areas unrelated to existing sponsored projects, cannot be supported by existing federal grants or contracts unless they specifically allow such charges. The Rivier Finance Office will be vigilant about interpretations of A-21 that clarify allowable and unallowable activities to be supported through federally sponsored projects.
Documenting and Reporting
The Finance Office will develop an augmented documentation process to maintain affirmative record keeping for faculty whose salary is derived more than 80% from sponsored projects to assure that federal funds are being allocated appropriately for salary support.
Salary Cap and Cost Sharing
Some sponsors, most notably NIH and other HHS agencies, impose a cap on the maximum rate or dollars that can be used in allocating salaries. Faculty should work with their administrators and the Finance Office to ensure compliance with sponsor imposed salary caps. Salary caps do not reduce the time commitment expected by the sponsor. The time commitment to the sponsor is based on the percentage of total effort the PI has stated that he/she will devote to the project in the approved proposal, not the percentage of salary charged to the grant.
Faculty may propose a level of time commitment, but not ask for salary support at the same level or not at all. Faculty should consult the policies of their respective divisions before doing so, and must be able to support the proposed effort from a non-grant source. If the proposal is funded, Rivier will be expected to document the salary that has been cost shared equal to the time commitment. The department administrator will work with the Finance Office to set the accounts to track the cost sharing. All salary cost sharing must be approved by the Controller or Vice President for Finance and Administration.