Proposed salaries and wages must be in accordance with University approved rates. Salary and effort of project personnel should be included in the budget.
Faculty Salary Charged to Grants
Regarding payments to faculty members from government grants and contracts, Marquette University adheres to federal policy as described in Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Grant.
- Because proposal budgets are submitted to sponsors in advance of the actual project start date, the amounts budgeted for salaries are necessarily estimates.
- Actual salary payments to faculty members will be based on salaries at the time the research is conducted and are subject to the availability of funds.
- Salary chargeable to grants is limited to the effort actually expended on the sponsored project.
- As with all other expenditures, salary charged to a grant must be reasonable, allowable by the University and the sponsor, and allocable to the project using the University's accounting and effort reporting systems.
Academic Year Salary
Generally, an employee may not receive more than his or her regular annualized salary by engaging in sponsored projects. Marquette faculty are typically employed for the nine-month academic year. An Individual's employment contract may specify alternative terms, depending on the nature of the appointment. All faculty members will have a contract stating the approved institutional base salary and the term to which that base applies.
Some sponsors, like NSF, limit the amount of salary that can be requested in a grant application. The NSF regulations can be found in the NSF Proposal and Award Policy and Procedure Guide (PAPPG). “….NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year.
Sponsor-Imposed Salary Caps
Some sponsors, such as NIH, impose salary caps that limit the amount of salary that may be paid to an individual. The University will comply with sponsor-imposed salary caps. This does not mean that the institution will decrease the employee's salary: sponsor-imposed caps only limit the amount of salary that the University can charge to the grant. Consult with ORSP regarding the policies of particular sponsors.
The NIH Salary Cap. The FY 2002 HHS Appropriations Act allows that "none of the funds … shall be used to pay the salary of an individual, through a grant or other extramural mechanism, at a rate in excess of Executive Level I" of the Federal Executive Pay Scale." The NIH policy defines he term "salary" as "direct salary" which is exclusive of fringe benefits and F&A 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.
For current NIH salary limitations, contact ORSP. See also the current NIH Guide notice regarding "Salary Limitation on Grants, Cooperative Agreements, and Contracts" The difference between the salary cap and the actual salary must be paid with non-federal funds. http://grants.nih.gov/grants/policy/salcap_summary.htm
Where the sponsor allows it, the difference may be included in the budget as cost-share. See the section in this manual on Cost Sharing for more information.
For Marquette faculty with a typical nine-month academic year appointment, summer salary for government grants is calculated on the basis of 1/9 of the academic year salary for each summer month devoted to the project. Faculty may charge up to three summer months to a grant.
- Where the sponsor allows it, and where a faculty member with a nine month contract elects to devote three summer months of effort to the sponsored project, the grant shall be charged 3/9 of the institutional base salary. The amount of salary requested must correspond to the amount of effort actually devoted to the project and be verified in the effort report.
- Faculty are reminded that compensation for effort is treated the same way regardless of the source of funds.
Salary Supplements and Extra Compensation
Salary charges to government grants, cooperative agreements, and contracts are allowable at the approved University base salary rate.
- Extra compensation over and above the approved base salary rate is not allowed except in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the faculty member is in addition to his or her regular departmental load.
- Exceptions must be endorsed by the appropriate dean dean at the time of proposal and explicitly identified as extra compensation in the proposal budget as approved by the sponsor when making the award.
- Salary supplements or extra compensation requested after the proposal has been submitted must be approved in writing by ORSP, the appropriate dean, and the sponsor (in that order).
Compensation for part-time faculty shall be charged at a rate not in excess of that regularly paid for the part-time appointment. Substantial changes in work assignments should, as a matter of course, prompt the appropriate dean and the employee to review the job description and base salary.
Consult the Office of the Provost website for current guidance on appointment procedures.
Consult with the department chair or ORSP for guidance regarding typical compensation levels for Graduate Research Assistants. Consult with the Business Manager for your college and/or the Office of the Provost for guidance regarding the forms and procedures required to hire and supervise graduate students. Fringe benefits are charged for Graduate Students. PIs should reference the Tuition Scholarship Credit Policy (http://www.brovik.com/grad/financial-aid-faculty-staff.php) regarding the inclusion of tuition credits in grant proposal budgets
Consult with the Student Employment Service in the Office of Student Financial Aid for guidance on appropriate compensation for undergraduates and the forms and procedures required to recruit, hire, and supervise them.
Limited Term Employees
Salaries and wages paid by sponsored projects to limited term employees must be consistent with the University's approved compensation levels for comparable positions. The Office of Human Resources has responsibility for the classification and compensation of employees and can provide help and guidance.
Salary Support for Personnel with Twelve-month Contracts
Generally, an employee may not receive more than his or her regular annualized salary by engaging in sponsored projects. All employees will have an approved maximum total compensation set by the University, which shall constitute that person's institutional base salary.
Administrative and Clerical Staff
The salaries of administrative and clerical staff are normally treated as Facilities and Administrative (F&A) costs. Direct charging of these costs may, however, be appropriate where a major part of the project or activity explicitly budgets for administrative or clerical activity and the individuals involved can be specifically identified with the project or activity.
Other Personnel Considerations
Key Personnel. NIH defines key personnel as individuals who contribute in a substantive way to the scientific development or execution of the project, whether or not they receive compensation from the grant supporting that project. NSF uses similar terms to identify the individual(s) responsible for the scientific or technical direction of the project. The Principal Investigator and collaborators are included in this category.
Naming an individual as key personnel in the application or proposal can have important implications for the award: Where key personnel are named in a sponsor's award notice, the sponsor's approval is typically required in the event a person named leaves the project or is replaced. All key personnel must disclose their financial interests, using the approved University Disclosure of Financial Interest form, before the proposal may be submitted to the sponsor. Where the project involves Human Subjects, key personnel must also receive appropriate training. Consult with the Office of Research Compliance for guidance.
Principal Investigator, Co-Principal Investigator, and Co-Investigator. Typically, a grant-funded project has only one Principal Investigator.
Co-Principal Investigators or Co-Investigators typically devote a specified percentage of time to the participating in the project under a consortium agreement, and are considered key personnel. NIH and NSF limit the number of individuals who may be named as Co-PIs: consult the sponsor's policy for guidance.
When preparing extramural proposals, PIs must follow established University policies and procedures governing the recruiting, appointing/hiring, and paying grant/contract personnel. These guidelines are meant to assure a smooth employment process and a prompt starting of the extramural award.
There are two ways to secure personnel for grant positions: (1) naming the individual(s) in the proposal, and (2) recruiting through regular University procedures.
University and non-University personnel can be named in the extramural application. PIs are encouraged to specifically name project personnel in proposals, where appropriate. These individuals should meet the qualifications of the positions and if they hold foreign national status, they must have the appropriate visa to come into the country and be employed. If the application is approved as submitted, no further posting/advertising is needed for these positions.
Positions for which the person is not named in the proposal are considered vacancies and must be posted or advertised in accordance with the University's equal opportunity/affirmative action policies.