I agree that the rule is ridiculous. As it stands, personnel are expected to pledge X% of their effort to a project, and we are expected to cover their salaries for that effort. If realistic wage increases are not allowed, we are then being asked to make a decision: either reduce effort or cost share. The standard FOAs for R01s, R21s, etc., state that cost sharing is not required. So while NOT-OD-12-036 is in effect, we will continue to use an average of the salaries we honestly anticipate having the pay from a grant's budget.

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