Hi Folks -

 I am enjoying, and learning from, the discussions about how to
handle faculty and staff who accrue annual leave rather than using it within
each sponsored project's budget period.
 One of our issues is that some approaches which work for other
institutions cannot work for ours.  For example: With respect to the
institution which increases its fringe benefit rate (as a direct cost to
each award) in order to develop a pool from which excess annual leave can be
taken, we can't use this because (1) all public university-controlled funds
in our State must be used by the end of the fiscal year...every year; and
(2) we have no Research Foundation which potentially could serve as the
"pooling" repository.
 Other issues/concerns relate to OMB Circular No. A-21 (revised),
"Cost Principles for Educational Institutions," which specifies (p.30) that
salaries, wages, and fringe benefits (for personnel on grants, contracts,
and other federal agreements) are allowable "...to the extent that the total
compensation to individual employees conforms to the established policies of
the institution, consistently applied...."
 It is this phrase, "consistently applied," with which we are
struggling.  For example, our current annual leave policy for 12-month
faculty and staff who are on regular institutional lines includes the
following statement: "If employees are unable or unwilling to use accrued
vacation, the appropriate Supervisor must show the number of vacation days
accrued on the Personnel Action Form used to terminate employment."  (Under
this circumstance, the terminating employee is entitled to receive a
lump-sum payment for all or most of the unused annual leave.)  ...  At the
same time, we are considering implementing the following policy for faculty
and staff who are supported by sponsored funds: "All accrued annual leave
associated with a sponsored project must be expended or the monetary
equivalent paid to the employee (in the case of termination) from the
(sponsored) account prior to the termination of the project.  Otherwise, the
annual leave will be lost."
 Our questions: (1)If we impose on "sponsored staff" a more
restrictive Annual Leave Policy than is offered to "regular staff," are we
in conflict with A-21 (revised)?  (2)If there is no issue, how should we
handle regular employees some or all of whose time is "bought out" by one or
more sponsored awards--e.g., are they now required to use proportional parts
of their annual leave as project periods come and go?  (3)Even if the
scenario in Question (2) is both legal and logistically manageable, how do
we - as research administrators - convince a full-time, regular faculty or
staff member to allow him/herself to be bought out to work on a sponsored
program when, by doing so, he/she accepts new restrictions on his/her annual
(and other)leave?
 Finally - [you're welcome; this had already become much too long!] -
our Indirect Cost agreement with our cognizant federal agency includes in
its base: "Direct salaries and wages including vacation, holiday, sick pay
and other paid absences but excluding all other fringe benefits (which are
included in a project's Direct Costs)."  Is one implication of this
agreement that our recovered Indirect Costs should be viewed as a resource
to be tapped when individuals on sponsored projects choose to take accrued
annual leave beyond the project period(s) when such leave was earned?
 Thanks for your insights, suggestions, and examples of how your
institution handles these and similar issues!

Howard Kaplan
Director of Research Services & Sponsored Programs
Georgia Southern University, P.O. Box 8005
Statesboro, GA 30460
(912-681-5465), (Fax: 912-681-0719), e-mail: <xxxxxx@gasou.edu>