UNIVERSITY OF SOUTH FLORIDA Office of Research Policies, Procedures, and Guidelines Guidelines RESEARCH Extra Compensation on Contracts and Grants PURPOSE: These guidelines are provided specifically for the payment of additional compensation from contracts and grants (projects) for work in excess of the established FTE for the position. To comply with federal and state regulations regarding compensation To allow personnel to be compensated appropriately for approved additional work To prevent over-compensation on contract and grant project accounts To provide a mechanism for processing extra compensation efficiently See Academic Affairs Policy Statement on Faculty Extra Compensation (rev. 8/7/03) http://files.acad.usf.edu/facprogdev/19945.doc. The approval of additional compensation on projects will be provided only under the conditions established in the policy above and these guidelines, and must be obtained prior to commencement of work. These guidelines apply to all projects regardless of funding source (federal, state or local government, private funding, etc.) and whether the project is cost-reimbursable or fixed price. EXCEPTIONS: Principal Investigators (PIs) and Co-principal Investigators (Co-PIs) are ineligible to receive additional compensation on federal or federal flow-through grants. Internal Awards, Convenience funds and Research Initiatives (RO) accounts may not be used to pay additional compensation under any circumstances. PROCESS: Obtain permission from sponsor prior to beginning work. A. Proposal Stage 1. The Principal Investigator should review these policies and procedures for Extra Compensation on Contracts and Grants to assure that any additional compensation being requested in a proposal to a Sponsoring Agency is in compliance with State and Federal regulations and University Policies and Procedures. In addition, the Principal Investigator should determine from the Sponsoring Agency that it approves of extra compensation for the project in accordance with OMB Circular A-21 and USF policies and procedures concerning said compensation. Rev. 6/1/09 2. The PI must include the following information in the proposal: a. That additional compensation may be paid from awarded funds to University employees in accordance with OMB Circular A-21 and USF Policies and Procedures concerning said compensation. b. When possible, the individuals (by name or position) who will be receiving additional compensation and the amount of that compensation; c. The work and services to be performed by these individuals. B. Award Stage 1. Sponsor Approval - The award document (or amendment) from the sponsoring agency must specifically state that additional compensation is allowed or implicitly approve of it by accepting the proposal with the extra compensation clearly identified in the proposal budget. 2. If extra compensation is approved by the sponsor and is in compliance with University, State and Federal policies, the Principal Investigator should submit a Request for Extra Compensation Form (http://www.usf.edu/usfpers/Forms/Appointments/dualcomp.doc) to the Division of Sponsored Research (DSR) for each person receiving extra compensation from the project (PIs and Co-PIs are not eligible to receive extra compensation on federal projects). C. Obtaining Permission after Grant is Awarded 1. If the grant is awarded without reference to Extra Compensation, the PI must contact the agency for written permission to allow it. Permission must be received by the DSR prior to submitting the Extra Compensation Form. a. PI works with the Secondary Employer to complete the Extra Compensation Form 2. PI submits Extra Compensation Form (for each person receiving extra compensation from the project) to the Division of Sponsored Research. DSR verifies that Extra Compensation is allowed on this project. If it is not allowed DSR returns the form to the PI. If allowed, the form is forwarded to Research Financial Management (RFM). 3. RFM checks to see if sufficient funds are available in the budget for this project. If they are not available the RFM notifies the PI and DSR. If sufficient funds are available, RFM signs the form in Section 9 and returns the form to DSR. 4. DSR obtains the signature of the VP for Research or designee and the approved form is returned to the PI or Secondary Employer. 5. The PI then obtains the Primary and Secondary Employer approval signatures (Sections 10 and 11) as well as the named employee’s signature of acceptance (Section 12) and sends the completed form to Human Resources for final processing. Rev. 6/1/09 RELATED REGULATIONS & POLICIES: A. External Office of Management and Budget: Circular No. A-21, Revised Subject: Cost principles for educational institutions. http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html H.10d. Compensation for Personal Services – Salary Rates for Faculty Members .d. Salary rates for faculty members. (1) Salary rates for academic year. Charges for work performed on sponsored agreements by faculty members during the academic year will be 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. Charges for work performed on sponsored agreements during all or any portion of such period are allowable at the base salary rate. 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. This principle applies to all members of the faculty at an institution. Since intra university consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full time base salary, the principle also applies to faculty members who function as consultants or otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution. However, 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 charges 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. (2) Periods outside the academic year. (a) Except as otherwise specified for teaching activity in subsection (b), charges for work performed by faculty members on sponsored agreements during the summer months or other period not included in the base salary period will be determined for each faculty member at a rate not in excess of the base salary divided by the period to which the base salary relates, and will be limited to charges made in accordance with other parts of this section. The base salary period used in computing charges for work performed during the summer months will be the number of months covered by the faculty member's official academic year appointment. (b) Charges for teaching activities performed by faculty members on sponsored agreements during the summer months or other periods not included in the base salary period will be based on the normal policy of the institution governing compensation to faculty members for teaching assignments during such periods. (3) Part time faculty. Charges for work performed on sponsored agreements by faculty members having only part time appointments will be determined at a rate not in excess of that regularly paid for the part time assignments. For example, an institution pays $5,000 to a faculty member for half time teaching during the academic year. He devoted one half of his remaining time to a sponsored agreement. Thus, his additional compensation, chargeable by the institution to the agreement, would be one half of $5,000, or $2,500. Rev. 6/1/09 B. Internal USF Policy Statement on Faculty Extra Compensation (rev. 8/7/03) http://files.acad.usf.edu/facprogdev/19945.doc Payment of Extra Compensation to Non-Faculty Employees on Federal Contracts and Grants There is no specified treatment in OMB Circular A-21for the payment of extra-compensation to nonfaculty. USF interprets non-faculty extra-compensation to be different from faculty extra-compensation in that there is no required cross-departmental component that must be met. To be eligible for non-faculty extra-compensation, the requestor must demonstrate that the activities to be performed by the non-faculty member are unrelated to the duties of their primary appointment and that the terms are specifically provided for in the agreement or have been approved in writing by the sponsoring agency. RELATED (Required) FORMS: A. Request for Extra Compensation Form (http://www.usf.edu/usfpers/Forms/Appointments/dualcomp.doc) B. Form Routing Instructions BEFORE WORK BEGINS, the Secondary Employer completes the Extra State Compensation Form for each person receiving extra compensation from the project (PIs and Co-PIs are not eligible). 1. The Secondary Employer completes sections 1, 2, 4, 5, and 6. a. Section 1: Enter the employee's name as it appears in GEMS b. Section 2: Enter the GEMS EmplID (Employee ID number) c. Section 4: 1) Enter the Campus name 2) Enter the College/Division name 3) Enter the Department/Unit name 4) Enter the GEMS Account number to identify the payroll funding source 5) Enter Pay Source (Contract, grants, other) 6) Enter the work schedule (Non-Faculty), identify the days and timeframe the employee is expected to work (e.g., M-F, 7PM - 10PM). If the hours for second job overlap with the primary job, the employee must provide a written explanation of how the secondary job will not interfere with the primary job (e.g., using accrued leave or taking an unpaid leave of absence) d. Section 5: Check the appropriate criterion (extra compensation qualifier) e. Section 6: Check the reason for the extra compensation (Contract or Grant) and provide the project details; Project Title, Project ID, Project Begin and End Dates, Location and Fund ID. f. Section 7: Enter the Secondary Appointment Begin and End Dates and the amount of Total Payment for the secondary appointment 2. The Employee completes Section 8 and signs the form in Section 9 3. The Secondary Employer signs in Section 10 and then forwards the form to the Primary Employer for approval (with a copy of the appointment paper) 4. Primary Employer completes Section 3 and obtains approval signatures for Section 10, then forwards the form to the Division of Sponsored Research (DSR) for approval. 5. DSR reviews to ensure the compensation is allowable and meets OMB Circular A-21 requirements for federal awards, signs in Section 12 6. DSR obtains Vice President for Research or Designee approval and then forwards the form to the Research Financial Management (RFM) Rev. 6/1/09 7. RFM verifies that funds are sufficient to support the Total Payment amount (from Section 7), signs approval and returns form to the Secondary Employer 8. The Secondary Employer forwards the form and the appropriate appointment paperwork to Human Resources. 9. Human Resources reviews the form to ensure proper procedures and approvals have been met and enters the secondary appointment into GEMS for payroll processing. Rev. 6/1/09