What about the text from NIH Notice 98-186: The term "salary" has been interpreted by HHS Legal Counsel to mean "direct salary", which is exclusive of fringe benefits and indirect costs/general and administrative expenses. "Direct salary" has the same meaning as the term "institutional base salary". An individual's institutional base salary is the annual compensation that the applicant organization pays for an individual's appointment, whether that individual's time is spent on research, teaching, patient care, or other activities. Base salary excludes any income that an individual may be permitted to earn outside of duties to the applicant organization -- Evelyn At 04:54 PM 9/9/99 -0500, you wrote: >Evelyn's last paragraph addresses an issue I was preparing to post: > >Our University has been struggling with the calculation of the institutional >base salary issue on NIH grants. Many of our faculty are physicians whose >University base salaries are relatively low (comparatively); however, their >clinical income compensates for that. When preparing NIH budgets, our >faculty are limited to requesting salary based on their University base >salary only - far below the $125,900 cap. This is based on A21, J8d(1) >which states: �based on the individual faculty member�s regular >compensation for the continuous period which, under the policy of the >institution concerned, constitutes the basis of his salary�. > >Our faculty have said they know physicians at other institutions who are >able to include their clinical income as part of their University base >salaries. Since clinical income is not guaranteed by our University, we do >not feel we are following A21 appropriately if we include that income. > >Do any of you have any experience with this or do your instituions interpret >A21 differently? We would love to help our faculty but want to stay within >the bounds of A21. > >In addition, if there is a way we can include clinical income as part of the >faculty's regular compensation for NIH awards, would this affect the >institution's IDC calculation/rate? > >Thank you in advance for your responses. > > >Nancy Nisbett > >____________________________________ >Nancy Nisbett, Director >Office of Research Administration >Phone: 405/271-2090 >Fax: 405/271-8651 > > >-----Original Message----- >From: Evelyn J. Ford [mailto:xxxxxx@MAIL.MED.UPENN.EDU] >Sent: Thursday, September 09, 1999 11:01 AM >To: xxxxxx@hrinet.org >Subject: Institutional Base Salary vs. Cap in Applications - Summary > > >Many thanks to all of you who responded to my query in July. There were 18 >responses. Although there was no direct response from anyone at NIH, a >number of respondents quoted interactions with NIH personnel, either >one-on-one or at SRA/NCURA seminars. The numbers are: > >1) Perform budget calculations on the cap AND enter the cap in place of >institutional base salary when necessary: 7. > >2) Perform budget calculations on the cap BUT cite the true institutional >base salary in all instances: 9 (only 1 respondent indicated that salaries >are sometimes left blank if the P.I. wishes). > >3) Perform budget calculations on and cite the institutional base salary: >2. > >NIH was a silent partner, though no direct response was received from >anyone at NIH; one respondent did quote a conversation with a specific >person at NIH. In all but one instance, method #2 was quoted as the NIH >preference. One person said that NIH had suggested that he use method #3, >that NIH would adjust at the point of award. > >A second question arose, which I directed solely to the original >respondents. Unfortunately, I didn't receive too many answers, and would >be most appreciative of further input from the group: Does your total >institutional salary include academic, clinical, administrative, and any >incentive pay, or do you cite something less than this? > >Thanks again to the lively discussions and comments I received! > >-- Evelyn > >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> >Date: Thu, 29 Jul 1999 08:10:01 -0400 >From: "Evelyn J. Ford" <xxxxxx@mail.med.upenn.edu> >Subject: Federal Salary Cap & PHS398 Form Page 4 > >I am interested in learning how various institutions are showing (or not >showing, as the case may be) and calculating salaries for individuals whose >compensation exceeds the federal cap. Are you leaving the institutional >salary column blank (PHS398 form page 4, when required) or inserting the >fed cap in that column, then performing the calculations on the cap? Do >you provide an explanation in the budget justification? If either one of >these two, have you been called by NIH at the time of an award to provide >the specific salary information even tho the award from NIH will be limited >to the cap as the base? Thanks for your input. > >---------------------------------------------------------------------------- >- >Evelyn J. Ford, Manager, Accounting Operations >Office of Research Support Services >School of Medicine, University of Pennsylvania >356 Anatomy-Chemistry Building >36th Street and Hamilton Walk >Philadelphia PA 19104-6061 >voice 215.573.1395 fax 215.573.8802 >xxxxxx@mail.med.upenn.edu ----------------------------------------------------------------------------- Evelyn J. Ford, Manager, Accounting Operations Office of Research Support Services School of Medicine, University of Pennsylvania 356 Anatomy-Chemistry Building 36th Street and Hamilton Walk Philadelphia PA 19104-6061 voice 215.573.1395 fax 215.573.8802 xxxxxx@mail.med.upenn.edu ===================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
