Fran,

My interpretation for "separate operation" is along the same lines as
"across departmental lines".  A separate operation would be a task such
as an analysis of samples or an statistical analysis provided as a part
of an overall research plan and the individual is NOT the PI or Co-PI.

The "remote operation" part is more difficult to explain.  I have had to
deal with individuals who say "well, lots of the work is done at the
industrial site".  But just being "remote" as in "off-campus" is not the
point of the regulation, I believe.  Maybe a good example would be,
Biologist A is leading a project in the rain forest on tree frogs.
Biologist B from his department is given extra compensation to join A in
the rain forest for limited time for an identification/analysis of the
plant that the tree frog eats.

I think the key issue with the extra compensation is that the individual
is providing a consulting service on a project primarily conceived by
and run by others.

I'll be anxious to see other responses.

Ruth Tallman
Office of Research and Sponsored Programs
Lehigh University
526 Brodhead Avenue
Bethlehem, PA  18015
Phone:   (610)758-3024
FAX:      (610)758-5994
E-mail:   xxxxxx@lehigh.edu

Fran Simpson wrote:
>
> According to OMB A21 J-8-d(1), extra compensation is permitted where
> consultation "...involves a separate or remote operation".  Can anyone
> clarify what this means?  Does this include a faculty member who on his own
> grant spends nights or weekends off-campus (such as providing evaluative
> services in a church basement) or travels to a different city to consult
> with colleagues, then pays him/herself for the extra time worked?
> Thanks,
>
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>   Fran Solano Simpson
>   Director, Office of Sponsored Programs
>   University of Denver
>   2199 S. University Blvd
>   Mary Reed Bldg, Rm 222
>   Denver, CO  80208-2121
>   Phone:        303-871-4036
>   Fax:  303-871-2623
>   Email:        xxxxxx@du.edu
>   Web:  http://www.du.edu/
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>
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