EAST CAROLINA UNIVERSITY
OFFICE OF GRANTS AND CONTRACTS
DHHS SALARY CAP
(US DEPARTMENT OF HEALTH AND HUMAN SERVICES)
.
THE FOLLOWING IS PROVIDED AS A BRIEF SUMMARY OF
THE HHS SALARY CAP REQUIREMENTS.
UPDATED AUGUST 2015
grantsc@ecu.edu
HHS SALARY CAP
•
DHHS IMPOSES A MAXIMUM SALARY CAP (ANNUAL SALARY RATE THAT CAN BE PAID)
FOR ALL OF THEIR AWARDS.
•
THE SALARY CAP RATE CHANGES PERIODICALLY.
•
THE RATE THAT IS IN EFFECT AS OF THE TIME OF AN AWARD, AND SALARY BEING
CHARGED, IS THE RATE THAT MUST BE USED.
•
PRIOR TO 12/11 THE SALARY CAP ONLY APPLIED TO NIH, AHRQ AND SAMHSA.
•
THE SALARY CAP NOW APPLIES TO ALL HHS AGENCIES.
– NIH, AHRQ, SAMHSA, CDC, HRSA, ACF, ACYF, AOA, ATS-DR, CMMS, FDA AND IHS
•
SOME NON-PROFITS, SUCH AS AMERICAN HEART ASSOCIATION, HAVE ALSO ADOPTED
THE HHS SALARY CAP RATE.
grantsc@ecu.edu
EFFECTIVE DATES
•
THE SALARY CAP IS BASED ON THE FEDERAL EXECUTIVE LEVEL II SALARY RATE.
•
FOR AWARDS ISSUED 10/1/14 THROUGH 1/10/2015, THE SALARY CAP IS
$181,500/YEAR (FOR 12 MONTH, 1.0 FTE).
•
FOR AWARDS ISSUED 1/11/15 THROUGH SEPTEMBER 30, 2015, THE SALARY CAP IS
$183,300/YEAR (FOR 12 MONTH, 1.0 FTE).
•
THE RATE MAY CHANGE AGAIN, WHEN THE 15-16 FEDERAL BUDGET IS PASSED, OR
IT MAY STAY THE SAME FOR A NUMBER OF YEARS.
•
CHANGES TO THE SALARY CAP ARE USUALLY ANNOUNCED IN JANUARY/FEBRUARY
BUT MAY BE RETROACTIVELY APPLIED.
•
OGC WILL NOTIFY THE CAMPUS WHEN THERE IS A CAP RATE CHANGE.
grantsc@ecu.edu
SALARY RATES
•
BECAUSE OF STAGGERED IMPLEMENTATION/AWARD DATES, AN INDIVIDUAL
COULD HAVE MORE THAN ONE CAP IF PAID FROM MULTIPLE HHS AWARDS OR A
COMBINATION OF HHS AND OTHER SPONSOR CAP AWARDS.
•
THE SALARY CAP IS A RATE OF PAY – NOT JUST A CUMULATIVE AMOUNT PAID OR
CHARGED TO AN AWARD.
• $183,300/YEAR MAX
• $15,275/MONTH MAX
• $7,637/PAY PERIOD MAX
•
EFFORT COMMITMENTS REMAIN THE SAME. IT IS ONLY THE RATE OF PAY THAT
MAY CHANGE.
•
THE CAP RESULTS IN MANDATORY COST SHARE FOR ANYONE WITH A UNIVERSITY
SALARY HIGHER THAN THE CAP.
grantsc@ecu.edu
EPAFs AND COST SHARE
• OGC WILL NOT APPROVE EPAFS THAT EXCEED THE APPROPRIATE HHS CAP
LIMITATIONS FOR HHS OR OTHER CAP AWARDS.
• ADMINISTRATORS SHOULD REVIEW FOR THE SALARY CAP RESTRICTIONS
WITH EACH NEW AWARD AND EFFORT REPORTING CYCLE.
• ANYONE REPORTING EFFORT ON A CAP AWARD, WITH A UNIVERSITY
SALARY GREATER THAN $183,300, WILL HAVE A MANDATORY COST SHARE
REQUIREMENT FOR EACH EFFORT PERIOD.
• EXAMPLE: $200,000 UNIVERSITY 12-MONTH SALARY, WITH 15%
MINIMUM EFFORT COMMITMENT AND MAX/CAP PAY IS $183,300/YR.
•
•
•
•
15% = $27,495 MAX PAY RATE, BUT
$27,495 = 14% UNIVERSITY SALARY, THEREFORE
EPAF SHOULD BE FOR 14% $$ EQUIVALENT AND
1% WILL BE REQUIRED COST SHARE TO MEET THE EFFORT
COMMITMENT.
grantsc@ecu.edu
COST SHARE continued
• EXAMPLE: $200,000 UNIVERSITY 12-MONTH SALARY, AND MAX PAY IS
$183,300/YR WITH 15% EFFORT COMMITMENT = $1,145/PAY PERIOD.
• EPAF PROCESSED AT UNIVERSITY RATE $200,000, IS $8,333/PAY PERIOD,
15% = $1,250/PAY PERIOD.
• AT EFFORT REPORTING TIME WITH 5 PAY PERIODS, TOTAL PAY SHOWING IS
$41,666.
• ERS GRANT PAY IS SHOWING AS 15% OF SALARY AT $6,250.
• BUT MAX ALLOWABLE IS $5,725 ($1,145 X 5 PP). IN ERS YOU WILL NEED
TO COST TRANSFER OFF $525 FOR A NEW TOTAL PAID OF $5,725.
grantsc@ecu.edu
COST SHARE continued
•
THIS WILL EQUATE TO 14% OF SALARY FOR THE EFFORT PERIOD.
•
A 1% COST SHARE WILL NEED TO BE DOCUMENTED IN ERS TO MEET THE 15%
EFFORT COMMITMENT.
•
IF CORRECTING HR REDISTRIBUTIONS ARE PROCESSED BEFORE THE EFFORT
PERIOD CLOSES ONLY COST SHARE WILL NEED TO BE PROCESSED IN ERS.
•
DEPARTMENTS NEED TO REVIEW CALCULATIONS EACH ERS PERIOD AS THERE ARE
DIFFERENT NUMBERS OF PAY PERIODS IN THE EFFORT REPORTING CYCLES.
•
FOR INDIVIDUALS WITH MULTIPLE HHS CAPS, DEPARTMENTS WILL NEED TO
MONITOR FOR DROP OFF DATES FOR THE “OLD” CAP AND START OF THE “NEW”
CAP FOR INDIVIDUAL AWARDS.
grantsc@ecu.edu
9-MONTH SUMMER SALARY
• SUMMER SALARY FOR 9-MONTH FACULTY WILL ALSO NEED TO FOLLOW
SALARY CAP REQUIREMENTS (IN ADDITION TO THE 133% RULE).
• MAX PER PAY PERIOD WILL BE $7,637.
• THE SUMMER EPAF MAY NEED TO BE LESS THAN THE NORMALLY
CALCULATED 100% ACTUAL SALARY PER PAY PERIOD.
• EXAMPLE: $145,000 FOR 9-MONTH, 133% = APPX $8,056/PP = 100% IN
SUMMER MONTH.
• ALLOWABLE MAX = $7,637/PP = APPX 93% OF UNIVERSITY SALARY RATE
CALCULATION.
grantsc@ecu.edu
9- MONTH continued
• FACULTY NORMALLY CANNOT COST SHARE IN THE SUMMER
BECAUSE THERE IS NO COST SHARE SOURCE.
– CANNOT COST SHARE FROM SUMMER SESSION TEACHING.
• SO THE SUMMER EPAF RATE MAY NEED TO BE LESS THAN THE
NORMALLY CALCULATED 133% SALARY RATE.
• THE CAP COULD ALSO POTENTIALLY AFFECT SEMESTER
BUYOUT CALCULATIONS FOR INDIVIDUALS WITH ANNUALIZED
SALARIES GREATER THAN $183,300.
grantsc@ecu.edu
CAP/EPAF CALCULATOR
• ON THE OGC WEBSITE THERE IS A SALARY CAP CALCULATOR
WHICH
– PROVIDES COMPUTATION ASSISTANCE TO PROCESS AN
EPAF IN COMPLIANCE WITH THE CAP REQUIREMENTS AND
– CALCULATES COST SHARE NEEDED WHEN COMPLETING
EFFORT REPORTING.
GO TO
– http://www.ecu.edu/cs-acad/grants/gc_forms.cfm
– SELECT “SALARY AND SALARY CAP CALCULATORS
grantsc@ecu.edu
CAP/EPAF CALCULATOR
• ON THE OGC WEBSITE THERE IS A SALARY CAP
CALCULATOR WHICH
– PROVIDES COMPUTATION ASSISTANCE TO
PROCESS AN EPAF IN COMPLIANCE WITH THE CAP
REQUIREMENTS AND
– CALCULATES COST SHARE NEEDED WHEN
COMPLETING EFFORT REPORTING. GO TO
– http://www.ecu.edu/cs-acad/grants/gc_forms.cfm
– SELECT “SALARY AND SALARY CAP CALCULATORS
11
QUESTIONS?
FOR ADDITIONAL INFORMATION, CONTACT
YOUR OGC REPRESENTATIVE
OR WRITE
ershelpdesk@ecu.edu or
grantsc@ecu.edu
grantsc@ecu.edu