WORKSHOP ON NEW NSF REQUIREMENTS April 28, 2009

New NSF Salary Policy

Prior policy limited salary compensation of senior project personnel totaling no more than two summer months across all of their NSF awards

New policy limits salary compensation for senior project personnel totaling no more than two months of their regular salary in any one year across all of their NSF awards.

Compensation in excess of two months must be specifically justified in the proposal and may not be charged unless approved in the award.

Senior Project Personnel - Defined

Principal Investigators (including Co-Principal Investigators) and Faculty Associates Faculty Associates are faculty members of the grantee

institution who will participate in project being supported by NSF.

Definition includes non-ladder rank academic appointees, such as professional researchers, if they are serving as PI or Co-PI on an NSF grant. Impacts NSF awards in which they are involved, but

not serving as PI or Co-PI.

NSF Salary Policy & Effort

NSF Office of Inspector General 100% salary in a period = 100% effort in same period

Individuals may not be engaged in any activities other than the performance of work under the award.

Impact Employees with multiple employment obligations to

the university cannot charge 100% salary Department chairs, Center Directors, etc. Ladder-rank faculty during the summer when engaged in

any activities other than research (writing proposals for new grants, teaching, committee service, outreach programs, etc.)

NSF Salary Policy & Effort

Salary to be charged to sponsored awards should be based on reasonable estimates of planned effort.

NSF’s policy allows for various effort patterns, so long as the total salary for an individual across all NSF awards does not exceed two months.

Yale University $7.6M Settlement

One Allegation Focused on Salary and Effort Yale researchers certified time and effort reports to

substantiate charging 100% of their summer salary to federal awards, but where the researchers had devoted significant effort to performing other, unrelated work.