I agree with Ruth's interpretation. First, there needs to be an institutional
policy on extra compensation that addresses what, when, and how. Assuming the
work of the faculty in question qualifies as "unusual", then the "separate" test
in this case would mean the extent to which the grant activity is a task defined
over and beyond the normal expectation for his employment. Additionally, the
activity has to be incidental and not routine, and explicitly approved by the
sponsor as work to be performed on an extra compensation basis.

Ruth Tallman wrote:

> 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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