Pop a Cap in Your Salary

Most people know by now that the NIH cap on compensated salary has been raised to $181,500, and that all new proposals should reflect this number in their budgets.  Budgets, though, have two distinct fields that rely on this number; what exactly do you do with it?

  1. The “Institutional Base Salary” field. You have your choice on how to handle this field.  You may enter the actual institutional base salary (even if over the current NIH salary cap) OR, if your investigator would prefer not to reveal actual salary, you can input the cap number ($181,500) and add  an asterisk (*).  If you use an asterisk, provide an explanation in the budget justification that the researcher has elected not to include actual salary information and a statement that the institutional base salary exceeds the salary cap (if applicable). If this option is selected, PIs must still submit one copy of the application to NIH that does include the institutional base salary. SPA prefers that you state the actual salary in your explanation if you elect not to include it in the budget worksheet, as this satisfies the requirement.
  2. The “Salary Requested” field. If your investigator is over the salary cap, your salary requested is the effort percentage multiplied by the salary cap.  For instance, if your investigator’s institutional base salary (note: do NOT include attachment or additional assignment amounts) is $200,000 and s/he will be devoting 10% effort to the project, your salary requested is [10% x $181,500] = $18,150.

This, of course, brings us to voluntary uncommitted cost sharing.  If your investigator is over the NIH salary cap, this means that his or her department must absorb the difference; this is known as mandatory cost share. Cost sharing must be requested and documented before the application is submitted, and the form can be found here.  To calculate how much your will need to request in cost sharing in a single year, you will need to determine the investigator’s institutional base salary (from Banner NBAJOBS screen) and the amount of effort the investigator will be devoting to the project:

[Non-Allowable Salary in a Year] = ( [Investigator Institutional Base] x [Investigator Project Effort] ) – ( [NIH Salary Cap] x [Investigator Project Effort] )

So, using the example numbers from above for an investigator with an institutional base of $200,000:

[Non-Allowable Salary in a Year] = ($200,000 x 10%) – ($181,500 x 10%)

= $1,850

Don’t forget to request the applicable fringes in each year as well; these are also considered to be above the NIH salary cap.  In our example above, we would request the department to pick up the the Wayne State University fringe rate 26.8% in addition to the salary over the cap.  Fringes, then, would be calculated as $1,850 x 26.8% = $495.80  The departmental cost share request for the year we just calculated, then, would be  $1,850 salary + $495.80 fringes, for a total amount of $2,345.80 in that year.  This downloadable spreadsheet may help you in your calculations; don’t forget to calculate each year of the project separately if you have included projected salary increases or adjustments in effort percentages in different years.

Modular Budgeting: Don’t Sweat the Details

Well, sweat the details a little bit.

 

Modular submissions to NIH calls for proposal are very attractive, especially due to the perceived lower level of scrutiny thee budgets receive (and, of course, the “25% Rebudgeting Rule” doesn’t apply to modular grants!).  If you have a project requesting $250,000 or less in direct costs in all years, your project is likely qualified for a modular submission (otherwise known as the “PHS398 Modular Budget component”).  Keep in mind, however, that you will still need to submit a detailed budget to SPA at the time of proposal submission; this is for accounting and set-up purposes once the project is awarded.

 

What do you need to know about submitting a modular budget?

A few things to keep in mind:

  • A modular budget is not accepted for SBIR and STTR grant applications.
  • There are only two justifications required for a modular budget:
  1.       You must include a personnel justification, including the name, role, and number of person-months for every person on the project. Note: salary and fringes are not to be discussed in the justification.
  2.       If you have a consortium or subcontract, you must have a corresponding justification which includes the total costs (direct + F&A), rounded to the nearest $1,000, for each consortium/sub.  Any personnel should have roles and person-months defined.  If the consortium is foreign, be sure to identify it as a foreign component.
  •  While not always required, you may also need to include an “Additional Narrative Justification” to explain any variations in the number modules requested annually.  Also use this section to describe and direct costs that were excluded from the total direct costs (equipment, tuition, etc) and any work being conducted off-site.

 

Why does SPA require a detailed budget if NIH only requires a modular for my project?

There are many reasons SPA requires a detailed budget in all instances, and why it’s a good thing for the PI:

  • Certain budgetary detail helps in determining exclusions from the base when calculating facilities and administrative (indirect) costs.
  • The PI can ensure that adequate resources are being requested for the proposed research activity.
  • Agencies can (and have) come back to ask for details; it’s good to have them at the ready.
  • Your detailed cost categories and amounts are used for budgeting loading once the project is awarded.

 

Modular budgeting saves time, effort and (oftentimes) agency scrutiny, but it doesn’t completely negate the need for detailed preparation.  For more detailed assistance on preparing a budget, check out the WSU-SOM Office of Research’s Proposal Prep page, or contact RAS for more specific guidance.

The Quick and the Deadlines

Grant submission is a team effort, and each member of the team has a stake in the outcome.  When an award comes in, the PI gets resources for important research, but there are also accountants who manage the flow of funds, managers who handle purchasing, specialists who ensure compliance, and the list goes on.  Lots of people put forth a lot of effort to ensure effective award management, and lots of people work at the front end as well to ensure the highest likelihood that the proposal for funds receives every consideration.  This is why there are internal deadlines for submission that predate the deadline for application imposed by the sponsor.  Sponsored Programs Administration (SPA) at WSU is responsible for submitting all external requests for funding on behalf of the University, and therefore need time to review and make sure that outgoing proposals are compliant.  SPA requires that all outgoing proposals be submitted three (3) full business days before the agency deadline for proper review (SPA’s policy can be found here).  The WSU School of Medicine also enforces this policy, and requires that all proposals submitted from any School of Medicine department after this deadline be acknowledged by the department chair and recorded in the School of Medicine Office of Research.  For the School of Medicine Late Submission Form and Policy, please follow this link.

An internal deadline is not meant to be a cruel imposition on already time-constrained researchers.  Rather, applications submitted on or before internal deadlines are given earlier and more thorough administrative reviews.  When a GCO or administrator is not in a time crunch, their reviews will be more valuable rather than just glancing through the application to verify the compulsory elements. When time is available
to give meticulous component review (such as  human subjects statements, budget justifications, conflict of interest, etc) it increases the likelihood of a smooth review of the application by the sponsor’s scientific review
panel. Extra consideration beyond the departmental office only improves the quality of the proposal, and ensures the elimination of errors that can be chalked up to haste.

A cursory survey finds that most major research universities impose a standard five-day internal deadline; as stated above, for now, WSU requires three.  To read more about other university standards and how they promote deadlines, check out NCURA’s article in the December 2010 issue of their magazine (p 18).

IPAs are 90 days

Today we are not talking about the ideal brew time lengths of a hoppy pale ale, but rather IPAs of the inter-institutional paperwork variety.  If your department has an IPA, you probably know that IPAs can be made for a period of up to two years and can be extended for an additional two year period. You may also know that it will take at least thirty days from the date the IPA agreement is generated by the VA for the processing and execution of the agreement.  But did you know that IPAs are only applicable to employees that have been with WSU for more than 90 days?  It’s true!  Read all about it on the OPM Hiring Authorities page.

For those who are unfamiliar with IPAs, the acronym stands for “Interagency Personnel Agreement.”  An IPA is a funding mechanism for the VA to reimburse departments within the WSU School of Medicine  for salary and fringe benefits  (a portion or all) of WSU employees working on sponsored research projects funded by the VA. Ideally this type of agreement strengthens the relationship between WSU and the VA through shared knowledge and resources.  Assignment agreements may be intermittent, part-time, or full-time, and the agency has the discretion of extending an assignment when the extension will benefit both organizations. Though the VA controls the terms of the assignment, the person on the IPA is still considered a WSU employee and retains all rights, benefits, duties and responsibilities associated therewith.  By agreeing to the IPA, WSU assures, at the completion of the assignment, the participating employee will be returned to the position that s/he occupied at the time the agreement was executed (or a position of like seniority, status and pay).

There are some limitations on IPA eligibility:

  • Post Docs and Graduate Students cannot be on an IPA
  • The WSU employee must be a full-time regular or part-time regular status employee for at least 3 months/90 days
  • Those residing in the US on a student visa cannot be placed on an IPA

If a VA investigator has notified you of an employee in your department that is a candidate and you are now  executing an IPA agreement, be sure to work with your GCO in SPA.  An IPA is classified as a “sponsored agreement” and  your GCO will help ensure that the IPA is properly recorded within university systems.  You will need to coordinate a letter/email to the VA that includes the employee’s salary, fringe, work location and supervisor, as well as the completion of the OF-69 form (likely this will be provided by your contact at the VA, but it is available on the John Dingell VA Medical Center website).  If you have any questions about process or eligibility, give us a call!