Doesn't the fact that this is a non-federal sponsor that allowed this
expense come into play?
My understanding is that A-21 applies to Federal grants only and is good
guidance for us for the non-federal sponsors for consistency's sake. Not
sure how this will play during an audit, though.

----- Original Message -----
From: "Herbert B. Chermside" <xxxxxx@VCU.EDU>
To: <xxxxxx@HRINET.ORG>
Sent: Thursday, June 03, 2004 9:45 AM
Subject: Re: [RESADM-L] Intra-University Consulting

> 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
> >
> >
> >======================================================================
> >  Instructions on how to use the RESADM-L Mailing List, including
> >  subscription information and a web-searchable archive, are available
> >  via our web site at http://www.hrinet.org (click on "Listserv Lists")
> >======================================================================
>
> 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
>
>
> ======================================================================
>  Instructions on how to use the RESADM-L Mailing List, including
>  subscription information and a web-searchable archive, are available
>  via our web site at http://www.hrinet.org (click on "Listserv Lists")
> ======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================