Not for a federal award, no. 2 CFR §200.430.h.2 specifies that for
universities, salaries are only allowable at the institutional base salary
rate. Besides, it's a bad idea (in my estimation, anyway) to do faculty
salary on an hourly basis anyway - they're salaried employees, so that's not
how they're paid normally. Converting to an hourly rate just creates more
work for you and confuses things when you're trying to reconcile effort
reporting.
There are some circumstances (ARPA-E being the most common) where a
sponsor's form requires you to enter an hourly rate (which always leads to
nightmarish amounts of fiddling as I tried to get enough decimals into the
spreadsheet to make the number match what it needed to be for our internal
budget), and you can't get around that. But I always footnoted those
worksheets to indicate that although we'd entered an hourly rate, it would
be paid and tracked in our internal systems on a monthly salary basis, as
that was how our personnel system was set up for faculty employees (and also
for a lot of technical staff).
To paraphrase Occam's Razor, "salary bases are not to be multiplied beyond
what is necessary."
Best,
Michael Spires, M.A., M.S., CRA
(He/him/his)
Research Development Officer, Sciences
The Research Office
Oakland University
256 Hannah Hall
244 Meadow Brook Road
Rochester, MI 48309-4451
(248) 370-2207
xxxxxx@oakland.edu
Past President, National Organization of Research Development Professionals
Oakland University has taken steps to slow the spread of COVID-19.
Nevertheless, the Research Office is available to faculty and staff for all
the research development, proposal submission, and award management services
that we routinely provide; please reach out to us through email (first
preference) or phone.
-----Original Message-----
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On
Behalf Of Elaine Brock
Sent: Thursday, June 25, 2020 9:47
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Charging Market Rates
Are there situations in which a university can charge "market rates"
(i.e., institutional base salary converted to an hourly rate than marked up
to be consistent with what the sponsor would pay to a for-profit company) to
a federal award either prime or sub?
If yes, what situations?
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