You are correct that extra compensation over base pay from a project is
generally unallowable, no matter who funds the project.  A-21 requires that
this principle be applied across the board.  There can be one exception.

If, and only if, your institution has a policy for overload pay for
overload work, and the sponsor and the institution agreed that this was an
instance of overload work, can such a payment be allowed.  In my
experience, an overload policy must be clearly restricted to relatively
short and temporary periods; a semester might be a typical maximum, and
approval should come from a high academic manager.  Otherwise it ceases to
be an overload.  I suggest that overload pay for an overload caused by
something other than a sponsored program come from a separate account, just
to keep the record straight that it is not an increase in base pay.

A-21 does allow for overload pay beyond the base pay if the policies are
clear and explicit.  In fact an overload could even be charged to a federal
project in a very unusual case if the sponsor explicitly agrees to it.  But
that is a might unusual case.

Many institutions have a broad prohibition against intra-institutional
consulting, regardless of departmental lines.  I believe this is a very
good idea.  "Consulting" should mean personal income from another source
than the home institution for personal effort outside of institutional
responsibilities.  Normal university business practices have changed since
the A-21 wording about consulting was adopted.  If a special "consult" is
needed, and takes more than incidental time -- say, an expert teaching a PI
a new technique -- it is much better to budget the expert for a very small
% effort.  If the expert devotes a week to that teaching, that can be
budgeted as 2% effort for a year.

Chuck

At 09:59 AM 6/3/2004, you wrote:
>Dear Colleagues,
>
>How do you handle requests from PIs for extra compensation payments from
>their grant or contract?   I received a call from a person whose request
>for extra compensation was rightly declined because the person is PI on the
>project from which the extra compensation was to be paid.  The nonfederal
>sponsor approved this arrangement, as did university administrators outside
>of the sponsored programs organization.
>
>I reviewed the OMB Circular A-21 J. 8. d. (1) exception with the  PI.
>Paying only base salary from grants is the rule under A-21.  The exception
>exists for faculty members who are carrying a full teaching, research and
>public service load and are also engaged in intra-university consulting
>with colleagues in another department.  I further noted that consulting for
>yourself would be a problem resulting in disallowed costs and raising
>concerns should the project in question came up as part of the audit
>sample.
>
>Please share any suggestions or war stories either via the list or offline.
>Thank you for your help.
>
>Ruth Smith, Executive Director
>Old Dominion University Research Foundation
>P.O. Box 6369; Norfolk, VA 23508
>Ph 757-683-4293, ext. 600
>Fax 757-683-5290
>Mobile Ph 757-469-5675
>
>
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Herbert B. Chermside, CRA
Special Asst. to VP-Research
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Voice:  804-827-6036
Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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