We have also interpreted the consistency requirement as not permitting the use of a project year since that definition varies from project to project and the requirement specifically says it applies to all projects.

NSF has apparently been moving away from enforcement of the 2-month rule in any case, since they now expressly allow it to be circumvented through rebudgets.  At this point it seems to be more a way to keep total proposal costs down than it is a rigid prohibition that NSF intends to audit, although we will continue to monitor NSF effort and treat it fairly rigidly so long as the requirement remains as currently written.  But this is a little bit of an odd rule the way things stand at the moment.

HTH,

-Adam

Adam Kuehn, Assistant Director
Office of Research Support
Duke University
2200 West Main Street, Suite 710
Durham, NC  27705
919-681-8689 (direct)
919-684-3030 (central)
xxxxxx@duke.edu

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Frederick, Jackie A.
Sent: Wednesday, January 31, 2018 11:38 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NSF: Defining "year"

We have always used the project period as the year, but with the language now stating "It is the organization’s responsibility to define and consistently apply the term “year”, as every project could have a different "year," we thought that with the inclusion of consistently in the definition, we were being required to use the same "year" for all projects despite different project periods.  Is it a consensus that we can just say we are using the project period as the year as long as that is what we are doing in every proposal?

Thanks,

Jackie Frederick
Director, PreAward
Wright State University

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Donna Berger
Sent: Tuesday, January 30, 2018 1:32 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NSF: Defining "year"

We've always defined it in terms of the project year - no more than 2 months per project year.

Donna Berger, Ph.D.
Director, Academic Grants
Marist College
Phone: 845-575-3670

From:	Michael Kusiak <xxxxxx@UCOP.EDU>
To:	xxxxxx@lists.healthresearch.org
Date:	01/30/2018 01:18 PM
Subject:	[RESADM-L] NSF: Defining "year"
Sent by:	Research Administration List
 <xxxxxx@lists.healthresearch.org>

I am looking for input how institutions have gone about defining “year” for the purposes of being compliant with the requirement in section in chapter II.C.2.g(i)(a)of the NSF PAPPG:

“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. It is the organization's responsibility to define and consistently apply the term "year", and to specify this definition in the budget justification. This limit includes salary compensation received from all NSF-funded grants.”

Of the public descriptions I have seen of being compliant with this requirement, I have seen fiscal year being used as the definition of “year.”

I could, however, see an argument to be made that you should maximize flexibility by simply defining “year” as the project periods defined in each award.

I understand that the overall issue is about that two-month limitation on salary support from NSF.

What’s the risk of defining a “year” as your institution’s fiscal year?

Thank you for any feedback you may have.

Mike

Michael Joseph Kusiak
Policy Resource Coordinator
xxxxxx@ucop.edu
510-987-0659

Research Policy Analysis and Coordination University of California, Office of the President

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