It is my understanding that "regular compensation" specified in A-21 applies to all payments for duties except something specifically defined as overload, no matter where the payment comes from. Can anyone else confirm this, or provide a defensible critique? Chuck At 11:06 AM 6/3/2004, you wrote: >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") >====================================================================== 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") ======================================================================
