GENERAL
Purpose
The following Process is established to ensure compliance with all federal and sponsor requirements regarding compensation that is charged to a federal project. The Process ensures the accurate identification and reporting of all costs associated with extra compensation (sometimes referred to "overload") as specified in OMB Circular A-21.
Administration
The Office of Sponsored Research is responsible for maintenance and review of this Process with input and comment sought from the Provost and the Stevens' Policy Task Force.
GENERAL DISCUSSION
Since faculty do not have a structured work period that would be analogous to a staff or administrative support person, i.e., faculty typically do not, and are not held accountable to, work a 35 or 40± hour week; thus, the concept of compensation for overload/overtime/extra compensation on a federally sponsored project is not generally recognized. OMB a-21, at J10d (1) states that "in no event will charges to sponsored agreements, irrespective of the basis of computation, exceed the proportionate share of the base salary for that period."
A-21 does allow for some limited degree of flexibility in this regard by stating at J10d (1) that:
"in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his regular departmental load, any charge 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."
After an award is received and in progress, the PI might determine that an unforeseen and unplanned event requires the consultation of another Stevens' faculty whose presence and compensation are best described by the verbiage shown above and stated at J10d (1) in A-21, i.e., "across departmental lines" or a "separate unit" and "such work [represents] extra compensation above the base salary" In these extremely limited cases extra compensation might be approved but only after submitting a request that describes the need and circumstances to the grant or contract official for approval. Otherwise, any Stevens' faculty presence on a sponsored project is at their base rate of pay.
Proposal Preparation and Submission:
- Specific mention in the proposal body that compensation and effort will be an overload, or extra compensation
- Specific mention in the budget justification that compensation and effort will be an overload, or extra compensation
- Specific explanation and justification regarding the need for the individual's presence in order to clearly describe the need for a normally unallowable compensation cost
Award receipt or during award:
- Specific identification on the payroll document that this represents extra compensation
- Contact OSR postaward specialist if need perceived after an award is received
- Ensure additional compensation does not change the technical/fiscal scope of the project
- Write a justification that describes the need for the individual, what has happened to require this person's presence now that wasn't anticipated at the proposal stage
- Forward justification to OSR postaward specialist, who will submit to the grants/contracting official at the sponsoring agency
|
