NSF budget revision Lori J Lafon 19 Mar 2015 09:43 EST
As Tricia Callahan pointed out, NSF no longer restricts salary to summer. Regarding whether approval is required to exceed 2 months, I also listened to the NSF webinar on 1/27 and was left unclear as to whether the 2 month salary limit is allowed if it is NOT in the approved budget, so emailed NSF's policy office and received the following response: (My question): It was clear from the webinar that approval to exceed 2 months’ salary is needed only if it constitutes a change in scope. If there is no change in scope does the non-federal entity need to communicate to NSF that this salary restriction has been exceeded? NSF answer: It is correct that NSF does not require prior approval to rebudget salary, unless it constituted a change in objective or scope, or funds were to come out of Participant Support Costs or go into Participant Support Costs-Other, both of which would require prior approval. NSF generally does limit salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This policy, however, does allow for flexibility to request more than two months of salary per year. If proposers request more than two months, the needed salary support should be put on the proposal budget and will need to be well justified in the budget justification. If more than 2 months is approved by NSF, it will be included on the NSF award budget. An awardee can internally approve an increase in person months devoted to a project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary rule. No prior approval from NSF is necessary. Again, the caveat is if the change would cause the objective or scope of a project to change, then the awardee would have to submit an approval request via FastLane. Since salary can amount to a large part of the budget, there may very well be a scope change with addition of salary, especially if, for example, the PI decided not to hire a graduate student in order to have enough money to cover the salary increase. Hope this helps! Lori ---------------------------------------- Lori LaFon Senior Grant Officer Office of Contracts & Grants University of Colorado Boulder 303-735-6597 xxxxxx@colorado.edu -----Original Message----- From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of RESADM-L automatic digest system Sent: Tuesday, March 17, 2015 10:00 PM To: xxxxxx@lists.healthresearch.org Subject: RESADM-L Digest - 16 Mar 2015 to 17 Mar 2015 (#2015-63) There are 14 messages totaling 4624 lines in this issue. Topics of the day: 1. Required University training for Research Administration? 2. Career Opportunity: Assistant Director Award Management, University of North Carolina at Chapel Hill 3. Pharmacy costs 4. Rates for Industry-Sponsored Research/Testing (2) 5. NSF Budget Revision (8) 6. The true culture of science? ---------------------------------------------------------------------- Date: Tue, 17 Mar 2015 08:18:38 -0500 From: Joanne Spitz <xxxxxx@PCG.WUSTL.EDU> Subject: Required University training for Research Administration? Hi everyone, Does your school/university require in-house training for Research Administration that leads to a certification of some sort? (for pre- and/or post award) If your University has something in place, would you be willing to share the content of the course or any info about how it is set up? Feel free to email me off-line if you prefer. Thanks! Joanne Joanne Spitz, CRA Research Administrator Anatomy and Neurobiology Washington University School of Medicine Campus Box 8108 660 South Euclid, St. Louis MO 63110 Phone: 314-747-6276 Fax: 314-362-3446 xxxxxx@wustl.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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 15:08:57 +0000 From: "Peoples, Vanessa L" <xxxxxx@EMAIL.UNC.EDU> Subject: Career Opportunity: Assistant Director Award Management, University of North Carolina at Chapel Hill The University of North Carolina at Chapel Hill is seeking an Assistant Director, Award Management in the Office of Sponsored Research. To review and apply, please click the link below. https://unc.peopleadmin.com/postings/71320 Vanessa L. Peoples Deputy Director, Office of Sponsored Research University of North Carolina Chapel Hill 104 Airport Drive, Suite 2200 Chapel Hill 27599-1350 919 962-4676 ~ xxxxxx@email.unc.edu<mailto:xxxxxx@email.unc.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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 11:20:47 -0500 From: "Mason, Kelly, M" <xxxxxx@CMH.EDU> Subject: Pharmacy costs Hello, I've been asked by my organization (a freestanding non-profit children's hospital) to solicit feedback on how pharmacy costs are determined at other institutions. If you are *not* using a service-center model, how do you determine appropriate pharmacy costs for federal grants? We're transitioning toward using the Medicare fee schedule, but we would also like to explore the options when an item is not on the schedule. Thank you in advance for any information you can give me! Replies can be sent directly to me at xxxxxx@cmh.edu<mailto:xxxxxx@cmh.edu>. Kelly Kelly Mason Manager, Research & Grants Administration The Children's Mercy Hospital 2401 Gillham Road Kansas City, MO 64108-4619 Tel. 816-701-1359 ________________________________ Electronic mail from Children's Mercy Hospitals and Clinics. This communication is intended only for the use of the addressee. It may contain information that is privileged or confidential under applicable law. If you are not the intended recipient or the agent of the recipient, you are hereby notified that any dissemination, copy or disclosure of this communication is strictly prohibited. If you have received this communication in error, please immediately forward the message to Children's Mercy Hospital's Information Security Officer via return electronic mail at xxxxxx@cmh.edu and expunge this communication without making any copies. Thank you for your cooperation. ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 17:18:38 +0000 From: "Bond, Chris" <xxxxxx@ALFRED.EDU> Subject: Rates for Industry-Sponsored Research/Testing Hello Colleagues, Would anyone at a university that does specialized testing for external industry sponsors be willing to help me out with a few questions? 1) If an individual laboratory containing specialized equipment that is used for industry-testing has not been set up as a "cost center/recharge/specialized service center, etc.", with its own cost-accounting structure, does your university allow the faculty member in charge of that lab to develop their own "price per sample/hour, etc." or does the university require that the project costs be identified/budgeted as personnel effort, supplies, overhead, etc.? 2) Is there a specific financial point in time, or criteria to be met, where one specific lab would be designated as a cost center, and go through the process of developing a formal "rate" for its services? Thanks for any help! ------- Chris Bond Director, Sponsored Research Administration Alfred University 607-871-2964 | xxxxxx@alfred.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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 18:39:04 +0000 From: "Davis Hamilton, Zoya" <xxxxxx@TUFTS.EDU> Subject: Re: Rates for Industry-Sponsored Research/Testing This is an excellent question and has come up for us as well. At our institution several labs (which are not service centers) occasionally use rates per sample or some other unit. We went back and forth discussing whether or not this is an acceptable practice, and agreed for now that we want a detailed cost category budget internally for each project to support this kind of pricing. We are planning to revisit this at some future point. How are others handling this? Thank you, Zoya Zoya Davis-Hamilton, Ed.D., CRA / Sr. Associate Director, Research Administration / Tufts University /136 Harrison Ave, Boston, MA 02111 / (617) 636-6709 / http://viceprovost.tufts.edu/researchadmin/ From: <Bond>, Chris <xxxxxx@ALFRED.EDU<mailto:xxxxxx@ALFRED.EDU>> Reply-To: Research List <xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>> Date: Tuesday, March 17, 2015 at 1:18 PM To: Research List <xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>> Subject: [RESADM-L] Rates for Industry-Sponsored Research/Testing Hello Colleagues, Would anyone at a university that does specialized testing for external industry sponsors be willing to help me out with a few questions? 1) If an individual laboratory containing specialized equipment that is used for industry-testing has not been set up as a “cost center/recharge/specialized service center, etc.”, with its own cost-accounting structure, does your university allow the faculty member in charge of that lab to develop their own “price per sample/hour, etc.” or does the university require that the project costs be identified/budgeted as personnel effort, supplies, overhead, etc.? 2) Is there a specific financial point in time, or criteria to be met, where one specific lab would be designated as a cost center, and go through the process of developing a formal “rate” for its services? Thanks for any help! ------- Chris Bond Director, Sponsored Research Administration Alfred University 607-871-2964 | xxxxxx@alfred.edu<mailto:xxxxxx@alfred.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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 12:46:59 -0600 From: Lori Johnson <xxxxxx@ISU.EDU> Subject: NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 15:45:46 -0400 From: Bonnie Kwit <xxxxxx@OAKLAND.EDU> Subject: Re: NSF Budget Revision NSF limits the salary amount to 2 months salary. Could be academic year or summer. Bonnie Kwit, CRA Grant and Contract Officer Oakland University Office of Research Administration 505 Wilson Hall (248) 370-4116 From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lori Johnson Sent: Tuesday, March 17, 2015 2:47 PM To: xxxxxx@lists.healthresearch.org Subject: [RESADM-L] NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 19:56:25 +0000 From: "Farnsworth, Franci" <xxxxxx@MIDDLEBURY.EDU> Subject: Re: NSF Budget Revision Actually, NSF now limits salary in proposed budgets to two months per year but doesn’t say anything about summer salary being preferred. At two presentations of the NSF policy office in the past year, I have heard staff say that the limitation applies to proposals and does not create a prohibition post award to approving a budget change such as the one you describe. However, they also say that institutions need to be sure that if they do allow such a budget change (increase in number of months spent on a grant) that they review carefully the following: - does such an increase constitute a change in scope? - does such a budget change have a negative impact on some other aspect of grant objectives? - doe such a budget change impact an outgoing proposal that is subject to the limit of two months per year for all NSF projects? I don’t think that NSF can give express approval for situations that fall under expanded authorities. But you probably can get the grants management specialist to confirm that you have the right to allow such a change, and the PI could get a program officer to weigh in on whether the plan is “reasonable”. Franci Vinal Farnsworth Associate Director of Grants & Sponsored Programs Middlebury College Middlebury, VT 05753 802.443.5889 From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lori Johnson Sent: Tuesday, March 17, 2015 2:47 PM To: xxxxxx@lists.healthresearch.org Subject: [RESADM-L] NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ============================== ------------------------------ Date: Tue, 17 Mar 2015 19:52:19 +0000 From: Scott Niles <xxxxxx@MOREHEADSTATE.EDU> Subject: Re: NSF Budget Revision Hi Lori, When I sat in the NSF Update webinar on 1/27/15, Jean Feldman stated that with all the changes in light of the new UG, no policy change had occurred with respect to the ‘2/9ths’ rule, and that all additional time must be justified and approved. Thus, I would say that the change does constitute prior approval from NSF. If the PI can justify the addition, you may not have any problems. Hope this helps! Scott Scott Niles, MA, CRA Grants and Contracts Administrator Office of Research and Sponsored Programs Morehead State University 901 Ginger Hall Morehead, KY 40351 Phone: 606-783-2278 Fax: 606-783-2130 Web site: http://www.moreheadstate.edu/research [cid:10113C0B-35C7-4235-9FDA-166BFDDEDFB8] From: Lori Johnson <xxxxxx@ISU.EDU<mailto:xxxxxx@ISU.EDU>> Reply-To: Research Administration Discussion List <xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>> Date: Tuesday, March 17, 2015 at 2:46 PM To: "xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>" <xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>> Subject: [RESADM-L] NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 15:49:43 -0400 From: "Callahan, Tricia" <xxxxxx@MIAMIOH.EDU> Subject: Re: NSF Budget Revision NSF started allowing 2 months salary, not just limited to summer, years ago. The issue is that only 2 months are generally allowed across all NSF awards regardless of summer or AY. If the re-budget is giving the faculty more than 2 months salary, then it would need NSF approval. I hope this helps. Tricia Callahan P.S. Also remember that while NSF no longer restricts to summer salary, your institution likely has guidelines on what is allowed and what is not allowed during contracted time. On Tue, Mar 17, 2015 at 2:46 PM, Lori Johnson <xxxxxx@isu.edu> wrote: > Hello, > Wondering if I could get input/opinions on a requested budget > revision. A PI has an NSF award that granted summer salary for senior > personnel. The PI would now like to re-budget more funds into the salary > line to take some academic year salary (a course buy-out) to dedicate more > time to the award. > NSF rules don't indicate this is a revision that needs approval, but > they also indicate they usually only award summer salary. > Would you allow this budget revision without express NSF approval? > Thanks, > Lori Johnson > > -- > Lori Johnson, MBA > Director, Sponsored Proj Accounting > Idaho State University > PO Box 8219 > Pocatello, ID 83209 > PH: 208-282-3899 > FAX: 208-282-5923 > > ====================================================================== > 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.healthresearch.org (click on the "LISTSERV" > link in the upper right corner) > > A link directly to helpful tips: http://tinyurl.com/resadm-l-help > ====================================================================== > -- [image: logo] *Tricia L. Callahan* *Director**, Proposal Development; Miami University Office for the Advancement of Research & Scholarship (OARS)* Tel: 513-529-1795 | Address: 102 Roudebush, 500 E High St, Oxford, OH 45056 xxxxxx@MiamiOH.edu <xxxxxx@MiamiOH.edu> | http://www.MiamiOH.edu/research <http://twitter.com/MiamiOH_OARS> <http://www.pinterest.com/MiamiOH_OARS/> *"**The mission of the Office for the Advancement of Research & Scholarship (OARS) is to encourage, facilitate, and support the Miami University community in its effort to obtain external funding for all forms of research, education, scholarly, creative, service, and outreach activities."* ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 14:14:52 -0600 From: Michael Spires <xxxxxx@COLORADO.EDU> Subject: Re: NSF Budget Revision Yes, I would approve it without a request to NSF. NSF stopped referring to “summer salary” in its guidelines quite some time ago, for just this reason. Here’s what the 2015 GPG has to say (http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_2.jsp#IIC2gia): “As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. …Under normal rebudgeting authority, as described in AAG Chapters II and V, an awardee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long as that change would not cause the objective or scope of the project to change.” Michael Spires, M.A., M.S. Senior Proposal Analyst Office of Contracts and Grants Woodbury 401, 572 UCB University of Colorado Boulder Boulder, Colorado 80309-0572 O (303) 492-6646 F (303) 492-6421 [cid:image001.png@01D060BC.BC48A520] NEW Uniform Guidance (2 CFR 200) is effective December 26, 2014! Questions? Contact your Proposal Analyst or Grant Officer or visit our website<http://www.colorado.edu/vcr/ocg-sponsored-research/omb-uniform-guidance>. From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lori Johnson Sent: Tuesday, March 17, 2015 12:47 PM To: xxxxxx@lists.healthresearch.org Subject: [RESADM-L] NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ========================== ------------------------------ Date: Tue, 17 Mar 2015 16:13:01 -0400 From: Carolyn Elliott-Farino <xxxxxx@KENNESAW.EDU> Subject: Re: NSF Budget Revision NSF does not require that salary be taken in summer. They limit salary to 2/9. However – and this is a big however – recent discussions on this listserve have revealed that one can apparently charge more than 2/9 once the award has been issued, if necessary. I still can’t quite wrap my head around this idea. If you will not exceed 2/9, go ahead and rebudget for a course release; you don’t need NSF approval. If this will put you over 2/9, it may be possible, but you might want to look into that. Hmmm – rereading your email, it appears to me that you do intend to charge more than two months salary. Check out the PAPPG: http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_2.jsp#IIC2gi (i) Salaries and Wages (Lines A and B on the Proposal Budget) (a) Senior Personnel Salaries & Wages Policy NSF regards research as one of the normal functions of faculty members at institutions of higher education. Compensation for time normally spent on research within the term of appointment is deemed to be included within the faculty member’s regular organizational salary. As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget.21 <http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_2.jsp#fn21> Under normal rebudgeting authority, as described in AAG Chapters II <http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/aag_2.jsp> and V <http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/aag_5.jsp> , an awardee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long as that change would not cause the objective or scope of the project to change. NSF prior approval is necessary if the objective or scope of the project changes. These same general principles apply to other types of non-academic organizations. As I mentioned above, some recent listserve traffic had corroboration from NSF about being able to charge more than two months salary. So --- if you have room in your budget, it would appear that you could rebudget to put more money for the PI. Carolyn From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lori Johnson Sent: Tuesday, March 17, 2015 2:47 PM To: xxxxxx@lists.healthresearch.org Subject: [RESADM-L] NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ------------------------------ Date: Tue, 17 Mar 2015 21:50:24 +0000 From: "Nelson, Heather (xxxxxx@uidaho.edu)" <xxxxxx@UIDAHO.EDU> Subject: Re: NSF Budget Revision From this listserv last October: Kris, Wow! This is very useful information on both counts, the rebudgeting and multiple projects. Thank you for going the extra mile for us and seeking clarity from the source. Now, everyone, make sure you save this email! Carolyn From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Duryea, Kris Sent: Tuesday, October 21, 2014 2:29 PM To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org> Subject: [RESADM-L] FW: NSF 2-month limit question Please see NSF’s response below. In a nutshell, the PI can charge more than 2 months a year if he/she received more than 1 award that had the 2 months budgeted. Kris From: Strausser, Beth A. [mailto:xxxxxx@nsf.gov] Sent: Tuesday, October 21, 2014 2:25 PM To: Duryea, Kris Cc: NSF POLICY Subject: RE: NSF 2-month limit question Hello Kris, Yes, if the funds were requested in the original budget and were reflected in the budget attached to the NSF award notice (which serves as NSF’s approval), then the PI may charge NSF for the full amount budgeted for each award received (in this case, 4 months total). Thank you, Beth Beth Strausser Senior Policy Specialist NSF Policy Office From: Duryea, Kris [mailto:xxxxxx@uncc.edu] Sent: Friday, October 17, 2014 4:19 PM To: Strausser, Beth A. Cc: NSF POLICY Subject: RE: NSF 2-month limit question Thank you, Beth. Just need a bit of clarity….Say a PI has 2 NSF awards and each included 2 months. So now the PI is funded for a total of 4 months. Does that mean the PI can charge the 4 months? If I understand your explanation below, the institution has the authority to allow the PI to increase his/her effort beyond the 2 months as needed. What’s not clear is if the PI was awarded more than one project, each with two months, can the PI then work for the full 4 months? Thank you for your patience. Kris From: Strausser, Beth A. [mailto:xxxxxx@nsf.gov] Sent: Friday, October 17, 2014 3:26 PM To: Duryea, Kris Cc: NSF POLICY Subject: RE: NSF 2-month limit question Dear Kris, Jean Feldman forwarded your e-mail to me for response. We apologize for the delay in getting back to you, but this has been a very busy time for the office. To answer your question, NSF generally does limit salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This policy, however, does allow for flexibility to request more than two months of salary per year. If proposers request more than two months, the needed salary support should be put on the proposal budget and will need to be well justified in the budget justification. If more than 2 months is approved by NSF, it will be included on the NSF award budget. When we implemented this policy, it is important to note that we did not add any new post-award prior approval requirements. That means that if, after an award is made, the PI or co-PI(s) find they need more time in order to successfully complete the project, an awardee can internally approve an increase in person months devoted to the project, even if doing so results in salary support for senior personnel exceeding the two month salary rule. No prior approval from NSF is necessary. The caveat is if the change would cause the objective or scope of the project to change, then the awardee would have to submit an approval request via FastLane. Since salary can amount to a large part of the budget, there may very well be a scope change with addition of salary, especially if, for example, the PI decided not to hire a graduate student in order to have enough money to cover the salary increase. I hope this information is useful to you. Beth Strausser Senior Policy Specialist NSF Policy Office From: Duryea, Kris [mailto:xxxxxx@uncc.edu] Sent: Thursday, October 09, 2014 8:31 AM To: Feldman, Jean I. Subject: NSF 2-month limit question I’m hoping that you can clarify the 2 month rule. There appears, on the surface, to be a conflict between the proposal guidelines and the FAQ on how to address the 2-month rule after award. The policy stipulates that if there are several proposals from an investigator all budgeting funds for the 2 months, there must be reference to it in the application. “In accordance with GPG Chapter II.C.2.g<http://www.nsf.gov/pubs/policydocs/pappguide/nsf14001/gpg_2.jsp#IIC2g>, NSF normally limits salary compensation for senior project personnel on awards made by the Foundation, to no more than two months of their regular salary in any one year. This limit includes salary received from all NSF funded grants. Salary is to be paid at a monthly rate not in excess of the base salary divided by the number of months in the period for which the base salary is paid. As such, proposal budgets submitted should not request, and NSF-approved budgets will not include, funding for an individual investigator or co-principal investigator which exceeds two months of their regular year salary. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice.” However, in the FAQ, it’s explained that the institution has the ability to increase the number of months charged to the project as long as the scope does not change. So, the question is – does the institution assume it’s okay to charge more than the 2 months because the PI received several NSF awards that each budgeted 2 months? I’m thinking no, that NSF only intended to pay for 2 months; that if the PI needs more than that, they would have to use the money received and not ask for more, which is essentially what’s going on when receiving multiple awards that each pay for 2 months. NSF Frequently Asked Questions (FAQs) On Proposal Preparation and Award Administration http://www.nsf.gov/bfa/dias/policy/papp/papp13_1/faqs13_1.pdf Must awardees request prior NSF approval if making a change post-award to the amount originally budgeted for senior personnel salary? NSF has not changed the terms and conditions or any of our post-award prior approval requirements. See AAG Exhibit II-1. Therefore, under the normal rebudgeting authority, an awardee can internally approve an increase in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the 2 month salary rule. No prior approval from NSF is necessary. The caveat is if the change would cause the objective or scope of the project to change, then the awardee would have to submit an approval request via FastLane. Since salary can amount to a large part of the budget, there may very well be a scope change with addition of salary, especially if, for example, the PI decided not to hire a grad student in order to have enough money to cover the salary increase. Thank you so much for your time. Kris Duryea Kristina Duryea, MA, GCRA, CRA Director of Research Development and Management College of Education | University of North Carolina at Charlotte 9201 University City Blvd. Suite 150, Charlotte, NC 28223 Phone: 704.687.7546 | xxxxxx@uncc.edu<mailto:xxxxxx@uncc.edu> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Ferland, Joyce H. Sent: Wednesday, October 08, 2014 11:15 AM To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org> Subject: Re: [RESADM-L] NSF 2-month limit question Hi everyone, I learned recently that under the normal rebudgeting authority, NSF allows institutions to internally approve an increase in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the 2 month salary rule. No prior approval from NSF is necessary. I was quite surprised to say the least. I have had a number of discussion with folks from NSF as well as from COGR to confirm since this FAQ seems to contradict the NSF two month rule. Please see the link to the Proposal Preparation and Award Administration FAQs, located at: http://www.nsf.gov/bfa/dias/policy/papp/papp13_1/faqs13_1.pdf. If you click on the link for “Senior Personnel” you will find the FAQ that describes NSF’s policy on rebudgeting salary post-award and how NSF approval is not needed for that, unless it results in a change of scope. NSF Frequently Asked Questions (FAQs) On Proposal Preparation and Award Administration http://www.nsf.gov/bfa/dias/policy/papp/papp13_1/faqs13_1.pdf Must awardees request prior NSF approval if making a change post-award to the amount originally budgeted for senior personnel salary? NSF has not changed the terms and conditions or any of our post-award prior approval requirements. See AAG Exhibit II-1. Therefore, under the normal rebudgeting authority, an awardee can internally approve an increase in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the 2 month salary rule. No prior approval from NSF is necessary. The caveat is if the change would cause the objective or scope of the project to change, then the awardee would have to submit an approval request via FastLane. Since salary can amount to a large part of the budget, there may very well be a scope change with addition of salary, especially if, for example, the PI decided not to hire a grad student in order to have enough money to cover the salary increase. Thanks! Joyce H. Ferland Director, Sponsored Programs Accounting Please note that I have been appointed to a special assignment, focusing my attention on the OMB Uniform Guidance regulatory changes and working in collaboration with Tufts’ senior leadership to define and execute the TEAM Research Administration vision. During my assignment with TEAM, please contact the Associate Directors of SPA, Kathy Young (Medford and Grafton campuses) and Cindy Matheson (Boston campus), for all matters related to the Office of Sponsored Programs Accounting. Thank you. From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]<mailto:[mailto:xxxxxx@lists.healthresearch.org]> On Behalf Of Duryea, Kris Sent: Wednesday, October 08, 2014 9:08 AM To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org> Subject: Re: [RESADM-L] NSF 2-month limit question I don’t agree. The policy guidelines specifically state that two months is the limit no matter how many NSF awards someone has. If the possibility of the extra months was not in the budget justification in any of the proposals, we can’t assume that the reviewers knew how the PI intended to manage this. My suggestion is to get clearance from the NSF grants person before giving the green light to the PI. While the award was made in reference to the proposal, if there was no mention of the additional months in the application, then we cannot safely assume we’re ok. “In accordance with GPG Chapter II.C.2.g<http://www.nsf.gov/pubs/policydocs/pappguide/nsf14001/gpg_2.jsp#IIC2g>, NSF normally limits salary compensation for senior project personnel on awards made by the Foundation, to no more than two months of their regular salary in any one year. This limit includes salary received from all NSF funded grants. Salary is to be paid at a monthly rate not in excess of the base salary divided by the number of months in the period for which the base salary is paid. As such, proposal budgets submitted should not request, and NSF-approved budgets will not include, funding for an individual investigator or co-principal investigator which exceeds two months of their regular year salary. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice.” Kris Kristina Duryea, MA, GCRA, CRA Director of Research Development and Management College of Education | University of North Carolina at Charlotte 9201 University City Blvd. Suite 150, Charlotte, NC 28223 Phone: 704.687.7546 | xxxxxx@uncc.edu<mailto:xxxxxx@uncc.edu> From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Kullie Kennedy Sent: Tuesday, October 07, 2014 4:59 PM To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org> Subject: Re: [RESADM-L] NSF 2-month limit question I would say it is deemed specifically approved when awarded. Note the language in the award letter: "The National Science Foundation hereby awards a grant of $0,0000,000 to The Regents of The University of Michigan for support of the project described in the proposal referenced above." The amount is included in the budget and justified in the budget justification. Consequently, an award that references the proposal and supplies a budget that mirrors the one proposed would satisfy my understanding that a greater-than-2-month salary has been specifically approved. On Tue, Oct 7, 2014 at 1:18 PM, Mary-Ellen Fortini <xxxxxx@scu.edu<mailto:xxxxxx@scu.edu>> wrote: That should have been mentioned in the "current and pending" and my understanding is that it cannot exceed 2 months in a year On Mon, Oct 6, 2014 at 5:23 PM, Schultz, Lori Ann Mcallester - (lschultz) <xxxxxx@email.arizona.edu<mailto:xxxxxx@email.arizona.edu>> wrote: Hello, all, I’m hoping you can spare a moment to email your procedures for managing the NSF 2-month salary limit for Senior Personnel. I am seeking clarification of a memo that is online which quotes an NSF senior policy representative saying the following: “As long as the person months are listed in the approved budget that’s attached to the NSF award notice, that constitutes NSF approval. No other approval is required.” Here is the scenario: PI submits several proposals over the course of several months, with each proposal requesting anywhere from 1.0 to 1.50 person-months of annual effort. The proposals include justification of the effort, but do not disclose the possibility that the 2-months would be exceeded across multiple grants for this PI. The PI has been awarded two projects, and now has a total of four active NSF projects, with budgeted effort across these projects totaling over 5 person-months per year. Each award document clearly states the person-months in the award budget, but there is no acknowledgment in the NSF award documents that the aggregate total across the PI’s four awards is greater than 2 months. I’d love for this group to weigh in on the scenario. The information we received from the NSF is different from what we have seen in NCURA and other presentations, and in audit findings, namely that the justification should include disclosure of exceeding the 2-month limit. Are you taking special steps at the preaward stage to add information on potentially exceeding 2 months in the budget justification? Are you reviewing expenses and removing salaries that exceed 2 months when this justification doesn’t appear in the application? Thanks in advance for your assistance! Lori Lori Ann M. Schultz Assistant Director, Sponsored Projects Services |The University of Arizona (520) 626-6308<tel:%28520%29%20626-6308> / (520) 626-4137<tel:%28520%29%20626-4137> fax Skype: lori.ann.schultz | http://rgw.arizona.edu | http://www.kuali.org ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== -- Mary-Ellen Fortini, PhD Director of Sponsored Projects St Joseph's Hall, 116 Santa Clara University Santa Clara, CA 95053 408-554-4806<tel:408-554-4806> (phone) 408-554-2389<tel:408-554-2389> (fax) Please consider the environment before printing this email. ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== -- Regards, Kullie ____________________________________________________________ Kullie Kennedy, Sr. Assistant Project Representative Direct: 734-763-6438 | xxxxxx@umich.edu<mailto:xxxxxx@umich.edu> Administrative Support Staff: Tracy Mausolf | Direct: (734) 764-4277 | xxxxxx@umich.edu<mailto:xxxxxx@umich.edu> Office Hours: Mondays - Friday 9:00 A.M. - 5:30 P.M. University of Michigan | Office of Research and Sponsored Projects (ORSP) 3003 S. State Street | 1042 Wolverine Tower | Ann Arbor, MI 48109-1274 orsp.umich.edu<http://orsp.umich.edu> Federal Team Sponsor Assignments<http://orsp.umich.edu/contacts/orsp/federal-team-sponsors.html> National Science Foundation<http://www.nsf.gov/> | Department of Energy ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lori Johnson Sent: Tuesday, March 17, 2015 11:47 AM To: xxxxxx@lists.healthresearch.org Subject: [RESADM-L] NSF Budget Revision Hello, Wondering if I could get input/opinions on a requested budget revision. A PI has an NSF award that granted summer salary for senior personnel. The PI would now like to re-budget more funds into the salary line to take some academic year salary (a course buy-out) to dedicate more time to the award. NSF rules don't indicate this is a revision that needs approval, but they also indicate they usually only award summer salary. Would you allow this budget revision without express NSF approval? Thanks, Lori Johnson -- Lori Johnson, MBA Director, Sponsored Proj Accounting Idaho State University PO Box 8219 Pocatello, ID 83209 PH: 208-282-3899 FAX: 208-282-5923 ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ========================================================== ------------------------------ Date: Wed, 18 Mar 2015 03:45:09 +0000 From: "Hathaway, Charles" <xxxxxx@NYMC.EDU> Subject: The true culture of science? If you haven’t read the recent article in Chronicle of Higher Education (March 16, 2015; “Amid a Sea of False Findings, the NIH Tries Reform”), Here’s a tidbit: Science today is riven with perverse incentives: · Researchers judge one another not by the quality of their science — who has time to read all that? — but by the pedigree of their journal publications. · High-profile journals pursue flashy results, many of which won’t pan out on further scrutiny. · Universities reward researchers on those publication records. · Financing agencies, reliant on peer review, direct their grant money back toward those same winners. · Graduate students, dependent on their advisers and neglected by their universities, receive minimal, ad hoc training on proper experimental design, believing the system of rewards is how it always has been and how it always will be. Read the rest. Not so good. Charlie Hathaway ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ==================================================================== ------------------------------ End of RESADM-L Digest - 16 Mar 2015 to 17 Mar 2015 (#2015-63) ************************************************************** ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ======================================================================