The NSF OIG just released a report last month of an audit at the University of Illinois at Urbana-Champaign in which they questioned salary costs on NSF grants exceeding 2 months. The report specifically references the NSF FAQ's. Below is an excerpt from the report:

UIUC agreed with our calculation of the excessive salary amounts charged to the NSF Awards
for these individuals; however, it stated that the Frequently Asked Questions (FAQs) document
on Proposal Preparation and Award Administration available on NSF’s website indicates that
grantees are not required to obtain NSF’s approval to exceed the two-month salary limitation. It
therefore does not agree with the questioned costs. While the responses to the FAQ’s indicate
that prior approval is not required from NSF to exceed the 2 month salary rule, the FAQ
responses do not represent authoritative guidance and therefore do not overrule NSF’s Award
and Administration Guidelines that require specific approval to allocate greater than 2 months of
salary to NSF during a one year period. As the FAQ’s do not override NSF policies, we have not
changed our opinion on this finding and the questioned costs remain the same.

I found this very surprising as I had assumed the NSF FAQ's would have been sufficient considering they came straight from NSF.

Nicole Whetstine
Grant Administrator
Office of Sponsored Research Administration
Embry-Riddle Aeronautical University
xxxxxx@erau.edu

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