Chuck, Are you saying that A-21 applies to all sponsored program funding? That's what your sentence, "A-21 applies to all payments for duties except something specifically defined as overload, no matter where the payment comes from," indicates to me. A-21's Applicability, the third section of this circular (the letter to heads etc.), clearly states, "All Federal agencies that sponsor research and development, training, and other work at educational institutions shall apply the provisions of this Circular in determining the costs incurred for such work." How do you interpret this as meaning that A-21 applies no matter who is funding the grant, or did I misunderstand your comment? Thanks. Carolyn >>> xxxxxx@VCU.EDU 6/3/04 11:39:44 AM >>> 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") ====================================================================== ====================================================================== 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") ======================================================================
