This topic is quite timely for me.  An issue has recently arisen about an exempt employee requesting
additional compensation on a federal award, above and beyond her regular pay.  Our institutional policy
otherwise allows this, as long as she can clearly document that the work is done on vacation days and
weekends.

I had always assumed that intra-university consulting on any federal grant was unallowable, but I'm not
so sure any more.

OMB Circular A-21 addresses the unallowability of intra-university consulting of faculty members.
Grant compensation for intra-university consulting is generally unallowable because it is "assumed  to be
undertaken as a university obligation requiring no compensation in addition to full-time base salary."
(J.8.d.(1))

However,  in J.8.a "Compensation for personal services, General" it states that  "Costs are allowable to
the extent that the total compensation to individual employees conforms to the established policies of the
institution, consistently applied..."   Paying a consulting fee to an exempt employee in our institution
seems to meet this criteria.  The paragraph goes on to say, "Incidental work (that in excess of normal
for the individual) need not be included in the payroll distribution systems...provided such work and
compensation are separately identified and documented in the financial management system of the
institution."

From what I am reading, it appears that faculty and staff are treated differently regarding the consulting
issue.  Is there something I am missing, or could it be allowable to legally pay a non-faculty staff
member additional compensation for work above and beyond the normal work load on a federal grant?

Brian Anderson, Director
Office of Research Development
Eastern Michigan University
email: xxxxxx@emich.edu

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