Hi Kris,

 

I learned recently that under the normal rebudgeting authority, NSF allows institutions to internally approve an increase in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the 2 month salary rule. No prior approval from NSF is necessary.   I was quite surprised to say the least.  I have had a number of discussion with folks from NSF as well as from COGR to confirm since this FAQ seems to contradict the NSF two month rule. 

 

Please see the link to the  Proposal Preparation and Award Administration FAQs, located at: http://www.nsf.gov/bfa/dias/policy/papp/papp13_1/faqs13_1.pdf.  If you click on the link for “Senior Personnel” you will find the FAQ that describes NSF’s policy on rebudgeting salary post-award and how NSF approval is not needed for that, unless it results in a change of scope. 

 

NSF Frequently Asked Questions (FAQs) On Proposal Preparation and Award Administration

http://www.nsf.gov/bfa/dias/policy/papp/papp13_1/faqs13_1.pdf

 

 

Must awardees request prior NSF approval if making a change post-award to the

amount originally budgeted for senior personnel salary?

NSF has not changed the terms and conditions or any of our post-award prior approval

requirements. See AAG Exhibit II-1. Therefore, under the normal rebudgeting authority,

an awardee can internally approve an increase in person months devoted to the project

after an award is made, even if doing so results in salary support for senior personnel

exceeding the 2 month salary rule. No prior approval from NSF is necessary. The

caveat is if the change would cause the objective or scope of the project to change, then

the awardee would have to submit an approval request via FastLane. Since salary can

amount to a large part of the budget, there may very well be a scope change with

addition of salary, especially if, for example, the PI decided not to hire a grad student in

order to have enough money to cover the salary increase.

 

Hope this helps.

 

Thanks!

Joyce

 

Joyce H. Ferland

Director, Sponsored Programs Accounting

 

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Kris Wolff
Sent: Thursday, July 24, 2014 12:02 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] language justifying more than 2 months NSF salary

 

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