ࡱ> cfb) Hbjbjʠʠ .z4h4h@<<<<<PPP8tTP!!PPPPP+++  $ #% <++ <<PP R<P<P  x` PkXc`C`  0!!,g&g& g&< +"Mey+++ +++!!g&+++++++++X : River Campus Summer Salary Guidelines FAQ Document This document contains questions from administrators related to implementation of the April 2022 Revised Summer Salary Guidelines as communicated from Stephen Dewhurst (Dean of Research). Background to the Summer Salary Guidelines The basic principle is that effort for a particular time period should be allocated such that it reasonably reflects the activities occurring during that time period. Since the summer is a distinct period of time (versus a semester or academic year), the summer effort allocation needs to reflect what is occurring during those months. Since faculty perform activities that are administrative and instruction-based during the summer, they likely cannot be 100% charged to sponsored project accounts. Question 1: Can effort shift between academic and summer periods? Proposals often include budgeted summer effort and budgeted academic year effort. Is it allowable to budget academic salary and then charge it in the summer or to budget summer salary and then charge it is the academic year? What if the program monitor states he/she will not fund academic year salaries, even though the agency is silent? Answer: In general, Expanded Authority allows re-budgeting of all costs; thus, these scenarios would be allowable, assuming correlation to how the effort is expended. There might be specific awards (most likely with contracts and small foundations) where the terms and conditions specifically prohibit any deviation from the budget. Administrators need to review the terms and conditions of particular awards and discuss with their ORPA RAs if guidance/clarification is needed for a specific award. Such situations need to be documented for AS&E Deans Office. Question 2: Payment of Effort in Excess of Commitment If the PI has only committed 1 month in his NSF budget but then performs effort of 2.5 months during the summer, can the full 2.5 months be charged, if there is enough remaining funds in the grant? Answer: In general, Expanded Authority allows re-budgeting of all costs; thus, this scenario would be allowable. Of course, the funds for the additional salary would need to be removed from other item(s) in the budget. Note that NSF does have a funding (not expenditure) limitation of two months of effort, but re-budgeting is allowed provided the research project has not changed in scope. Question 3: Are accelerated compensation arrangements acceptable? Can a faculty member expend efforts in June, July and August but elect to have the compensation fully paid to them in June and July (i.e., pay half of August with Junes salary and the other half of August with Julys salary). Answer: This is not acceptable. The URs payroll system and effort system are one and the same. The pay in a period should coincide with effort expended in that same time period and be allocated according to the activities that benefited from such effort. Additionally, for projects where reimbursement is through a letter of credit or periodic invoicing, the cost and reimbursement will not be concurrent with the effort expended. Question 4: Projects Ending During the Summer A sponsored project ends 6/30/2022 and the agreement specifically states that no academic salary can be charged. The professor is devoting 100% of his effort on this project the last month (June 2022) in order to finish the work. Can 100% effort be charged for the month of June 2022? Answer: There will be a few circumstances whereby the specific terms and conditions of a project preclude adherence to the guidance (please refer to Question 1). Additionally, there might be cases whereby the faculty member is truly devoting his/her entire effort during the last month of a project because it will end and not be extended. Such situations need to be documented for AS&E Deans Office. Question 5: How Does the NIH Salary Cap Impact the Summer Salary Guidance? Faculty earning over the cap for NIH purposes are now only allowed to use departmental funds to charge the amount over the cap to pay themselves at their full salary. Consider this example: A faculty member earns an academic year salary of $200,000 (monthly salary of $22,222). The NIH salary cap of $203,700 only allows us to charge $16,975 per month to the sponsored project (assuming 100% effort for that month). This faculty member had 17% effort in a given academic month. The faculty has committed 1 month to the grant. Assume prospective academic year salary is equivalent to current academic year salary (i.e., no pay increase). Scenario 1 How will academic year salary recovery be used to compensate the faculty and how does the salary cap factor in? Answer: To properly implement the policy for this example, the monthly charges would be as follows: Academic Month: Sponsored Project Salary $ 2,886 (sub ledger 5) (17% of $16,975) Salary cap 892 (sub ledger 2) (17% of $22,222 less $16,975) Academic Year Salary 18,444 (83% of 22,222) Total Pay $22,222 Summer Month: Academic Year recovery $3,778 (17% of $22,222) Sponsored Project Salary 14,089 (subledger 5) (83% of 16,975) Salary Cap 4,355 (subledger 2) (83% of $22,222 less $16,975) TotalCompensation$22,222 In Summary: Salary Cap: $ 5,247 Non-Sponsored Project Salary (sub ledger 2 or 3) 22,222 Sponsored Project Salary (sub ledger 5) 16,975 Total Pay (2 months) $44,444 Scenario 2 Should only .83 of the capped salary amount be charged to sponsored projects for each of the summer months? Answer: Yes, this is appropriate according to the guidelinesunless the facultys appointment is a rare and special circumstance (100% research with no other administrative or instructional duties). Question 6: Can Summer Compensation be Deferred? Scenario 1 May a professor defer all of his/her summer compensation until September (then be paid in full)? In this way, there is minimal guess work regarding how time was spent between activities. Scenario 2 Is it acceptable for a professor to request a smaller fraction of a month (e.g., .5 month for each month) and then submit a revised summer comp form at the end of the summer to reflect additional levels of effort (and additional pay)? Answer to Both Scenarios: These scenarios circumvent the effort reporting system that needs to be applied to all personnel. Effort must be allocated, as incurred, to the accounts reasonably expected to benefit from such effort. Corrections are made ifupon look-back (end of summer for this purpose)the allocations are deemed to be not reasonable based on how the actual work was performed. Question 7: Working Less Than Originally Planned May a faculty member return pay because they did not work as much of the summer as they initially planned? Answer: This situation should occur only in unforeseen circumstances (e.g., out-of-town family emergencies, death or sickness requiring an extended period of absence). Effort has been committed on sponsored projects that are funded, thus the amount of effort required for the summer should be understood in advance of the beginning of summer. If effort is committed on sponsored projects, but the person does not perform the work (thus returns funds) there are many compliance issues that arise (most requiring informing and obtaining approval from the sponsor). When an employee returns pay, there are implications regarding correction of the payroll taxes, withholdings, benefit contributions, et cetera. The result is additional administrative burden. Question 8: May Allocations Be Determined Concurrently? If a professor does not have his/her summer plans finalized is it acceptable for them to submit a Form 211S month by month for summer compensation? Answer: If summer effort was committed in proposals, it should be understood how much effort the individual needs to put forth in the respective summer. Regardless, this scenario cannot be permitted. First, this proposed situation circumvents the effort reporting system that needs to be applied to all personnel. In general, the amount and allocation of the payment for the summer period should be completed on one form (currently a Form 211S) using a blended allocation, unless it is known that a blended allocation will not fairly represent efforts to be expended in each particular month. During any appointment period, effort must be allocated, as incurred, to the accounts that are reasonably expected to benefit from such effort. Corrections are made ifupon look-back (end of summer for this purpose)the allocations are deemed to be not reasonable based on how the actual work was performed. Question 9: Can There Be Extra Compensation in the Summer? A faculty member is running an experiment off-site for 4 weeks, 7 days a week since there are limited personnel to take shifts. The following month, the faculty member will be on vacation (for the entire month). Can the faculty member be paid 1.25 times their monthly salary? Answer: A person can never have more than 100% effort. The UR effort system and the UR payroll system are one and the same. The payment for the month represents compensation for all of the individuals efforts to accomplish their responsibilities to the UR during that month. Generally, the payment must reflect one-ninth of their academic year salary. Recall that extra compensation is not part of the persons 100% effort. Extra compensation paid from sub-ledger 5 accounts should be extremely rare (especially with regards to a Principal Investigator) and represent significant risk that is best to avoid. It might be possible for the Department Chair to justify extra compensation if the principles of 2 CFR 200 are satisfied (i.e., not violated) and the UR policies regarding extra compensation are met. There must be documented, extenuating circumstances to support any extra compensation that is paid. Question 10: How to Charge 2.5 Months A faculty member has 2.5 months of summer salary. He/she has scheduled a 2 week family vacation and is working 2 full months on sponsored projects and .5 month on other activities. Can the effort allocation be 100% to research for two summer months, with the third month being charged to non-research? Answer: It will be acceptable to charge .83 to research and .17 to unrestricted accounts for each of three months. (This assumes it reasonably approximates the effort being devoted.) Question 11: Can Effort be Volunteered? Scenario 1 Faculty often perform administrative academic functions during the summer, in addition to their research. Is it satisfactory to only charge .83 of a month to the sponsored account and then not request compensation for the remainder of the month (i.e., for the administrative/academic time)? Answer: Certain non-research responsibilities of a faculty members 9-month appointment are often performed outside of the boundaries of the 9-month academic period. Examples include writing of competitive grant proposals, involvement in department administration and academic counseling of students. If a faculty member did not elect to work during the summer period, yet performed these non-sponsored activities during the summer, they should be inconsequential in the aggregate. Such work is understood to be included in the responsibilities of the 9-month appointment and the 9-month appointment base salary considers these activities. When a faculty member elects to work primarily for sponsored activities during the summer period, the non-sponsored activities of the first paragraph still occurin fact, there is likely a greater level of such activity due to the members campus presence during the summer period. Prior audits at peer institutions support a viewpoint that some non-sponsored activity occurs because of electing to work during the summer period. The 17% per month in the April 2022 Revised Summer Salary Guidelines is a suggested estimate of the amount of such activity. If the faculty member is performing only sponsored activities during the summer period, obtain Deans Office sign-off and allocate their payroll 100% to sponsored (ledger 5) accounts. If the faculty member is performing non-sponsored activities beyond the residual from their 9-month appointment (refer to first two paragraphs), this non-sponsored activity should be estimated and charged to non-sponsored (non-ledger 5) accounts, with the remainder charged to sponsored (ledger 5) accounts. The URs payroll system and effort system are one and the same. Payroll allocations need to reasonably reflect all activities the person is performing in fulfillment of their University responsibilities. Scenario 2 When committed effort is expended during the academic yearbut is not charged to the sponsored account during the academic yearthe effort is considered cost sharing. Hypothetically, if there is committed summer effort for a sponsored project, may a faculty member expend the effort but choose not to receive summer compensation for such effort? Would this hypothetical situation be considered cost sharing? Answer: The hypothetical situation would not qualify as cost sharing since a cost share expenditure is a transaction that is paid for from non-sponsored funds. In this hypothetical situation, the effort is not paid. This scenario would be problematic for the purpose of documenting that the effort actually occurred. Effort must be documented (i.e., it must be traceable in the effort/payroll system as either a direct charge to the respective project or as a charge to an unrestricted account). In this scenario, the summer effort would not be traceable in the effort/payroll system (since there is no pay), thus the Office of Inspector Generals perspective would be that the effort was not incurred absent other acceptable documentation. Should a faculty member propose such a hypothetical situation, the proposed arrangement needs to be brought to the attention of the AS&E Deans Office. Question 12 Less than one summer month is being expended A faculty member is working a whole month. He will spend time on an NSF project and will also be working on a proposal. He only has a limited amount of funds left on his award. It equates to 80% of a month of salary and will be his entire summer compensation. Is it acceptable to charge all the compensation to the NSF award because it is less than one months regular pay, or would a portion of that months pay be allocated to an unrestricted account to give recognition to the proposal activity? Answer: In general the Guidelines are deemed not to apply if a faculty members summer compensation is less than one full month. Any non-project activity that might occur is deemed as de minimis compared to the project activity that is occurring. Question 13 Is Summer Compensation always to be paid in equal thirds? A faculty member has one NSF award. In the academic period .5 months effort is charged (and at least .5 months of effort is performed). The faculty member is requesting summer compensation of 1.5 months. In addition to work on the project, there is likely to be some proposal writing and also some course preparation for fall 2022. The faculty member is taking two weeks vacation in July and a few days (maybe a week) vacation in August. Can the compensation be paid out in equal thirds for the months of June, July and August? Response: Generally, for ease of administration, it is permissible to make equal payments during the summer months the individual is expending effort, unlessin the judgment of the faculty member and administratorit results in materially insufficient matching of payments with the occurrence of the effort. 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