Re: Faculty Payments above base salary
gary chaffins 29 Mar 1995 17:27 EST
Supplemental pay is extremely rare at our institution because of our
research orientation. Interdisciplinary activities are expected as a
matter of normal faculty commitment.
I would suggest that you review the Cost Principles in Office of
Management and Budget Circular A-21 particularly section J 8
"Compensation for Personal Services" to determine if your practice or
intended practice meets with this pronouncement.
This section is subject to interpretation by your particular
institution, your outside auditors and agency grant or contract
officers. The more liberal the interpretation by the institution the
greater the potential for audit findings.
Note especially J 8 d. Salary rates for faculty members
1. Salary rates for academic year ... "Since intra-university
consulting is assumed to be undertaken as a university obligation
requiring no compensation in addition to full-time base salary, the
principle also applies to faculty members who function as consultants
or otherwise contribute to a sponsored agreement conducted by another
faculty member of the same institution."
This section goes on to read "However, in UNUSUAL (emphasis added)
cases where the consultation is across departmental lines or involves
a separate or remote operation, AND (emphasis added) the work
performed by the consultant is in addition to his regular departmental
load, any charges for such work representing extra compensation above
the base salary are allowable provided that such consulting
arrangements are SPECIFICALLY PROVIDED FOR IN THE AGREEMENT OR
APPROVED IN WRITING BY THE SPONSORING AGENCY (emphasis added)."
As "insurance" I suggest that you:
a. define: full time duties of the faculty member in question
so that it is clear when effort that exceeds full
time is identifiable.
A question you may want to ask is: "What does your
institution's appointment contract, faculty
handbook etc. describe as a normal duties of a
faculty member."
separate or remote operation: is it clear and
definable
(If you get these taken care of, you are in great shape)
b. compensation should be based on regular rate for the
academic year
c. get the required approvals
In regard to the effort reporting or activity reporting question.
I recommend paying in such a way as to avoid inclusion in your "100%"
activity reporting system. This will avoid any obvious impact in the
percentage distributions and will not serve you well in trying to
distinguish this "extra effort" from their regular duties. A "piece
work" method based on an appropriate percentage of their base pay rate
could be in order. If you can process the compensation for the extra
work AFTER the completion of the effort this could constitute your
after the fact reporting requirement; if the nature of the work is of
sufficient duration that a forecast method of payment is necessary
(appointment of the additional compensation through future pay
periods) then, if possible pay on an activity reporting excluded pay
code and have the project director/faculty member complete a separate
post effort activity report.
Gary Chaffins
Director
Office of Grants and Contracts
University of Oregon
xxxxxx@OREGON.UOREGON.EDU
(503) 346-2395