I. OBJECTIVE & PURPOSE
Federal rules and regulations, including Federal Uniform Guidance (UG) found at 2 CFR 200, do not allow for an individual's Institutional Base Salary (IBS) to be increased as a result of obtaining grant funding. These federal rules and regulations also restrict the payment of overload, bonus, or other supplemental payments outside the individual's IBS. Accordingly, the following policy applies to compensation paid to individual employees from a contract or grant, whether in whole or in part, and inclusive of employees who have committed effort to a contract or grant but who are not receiving compensation (also known as "cost sharing"). This policy is in addition to other University of North Florida regulations, policies, and guidelines regarding employee compensation and the allowability of supplemental compensation (e.g., 2.0440P and 4.0110R), as well as the UNF-UFF Collective Bargaining Agreement.
Institutional Base Salary (IBS) is the compensation paid by the University for an employee's 1.00 FTE appointment, whether that individual's time is spent on research, teaching, administration or other activities. IBS includes an individual's regular salary (e.g., academic appointment) and salary/stipend from any additional assignment (e.g., chair of a department), regardless of the source of the funding to the University. IBS is established by the University in a letter, appointment form, or other written document. It does not include Extra Service Pay (ESP). Also excluded from the IBS is salary paid directly to an individual by an organization outside the University. The written definition of work covered by IBS, as required by OMB Uniform Guidance, 2 CFR 200.430(4)(ii), must be "specific enough to determine conclusively when work beyond that level has occurred."
Extra Service Pay (ESP) is compensation for any services that are clearly documented as above and beyond an employee's university appointment or position and the associated IBS. This also includes honoraria, awards, bonuses, or internal overloads during the appointment period on which the IBS is based. The source of funds is irrelevant when determining whether compensation is extra service pay.
III. STATEMENT OF POLICY
IBS may not be increased as a result of replacing University salary funds with sponsored projects funds.
Unless there is prior approval by the sponsor, charges of an employee's salary to a contract or grant must not exceed the proportionate share of the IBS based on the certified percentage of effort applied to the contract or grant for the period. Charges for work performed by employees with less than 12-month appointments on contracts or grants during periods not included in their IBS (e.g., summer) will be at a rate not in excess of the IBS. Charges for work performed on contracts or grants by employees having only part-time appointments will be at a rate not in excess of that regularly paid for part-time assignments.
Certain sponsors (e.g., NIH) impose a limit/cap on the rate of salary they will reimburse. An individual's IBS, rather than the capped rate, is used when calculating percentage of effort and the difference between the capped rate and the individual's IBS is accounted for as cost sharing in order for the University to meet the requirements of the Cost Accounting Standards incorporated in UG.
Internal overload payments (sometimes referred to as "supplemental compensation") may not exceed 0.25 FTE in aggregate above the IBS. They are allowable only under the following conditions:
Intra-Institutional Consulting: Intra-institutional consulting by faculty (e.g., providing statistical or foreign language assistance on a contract or grant) is assumed to be undertaken as an institutional obligation requiring no compensation in addition to IBS. However, faculty may receive internal overload payments when consulting on contracts or grants for which they are not listed as a Principal Investigator when all of the following criteria are met:
- The work will be carried out across departmental (or comparable unit) lines or at a separate or remote location;
- The work performed will be demonstrably in addition to the faculty member's regular departmental (or comparable unit) load; and
- The award document for the contract or grant acknowledges that this additional compensation is allowed, or approval is obtained from the sponsor to receive the overload payment.
In all cases when sponsor approval is required, it must be obtained prior to charging the extra compensation to the contract or grant. Documentation of sponsor approval must accompany the request for extra compensation. Compensation charges in excess of an individual's IBS must be at a rate not in excess of the IBS rate. Requests for extra compensation from a contract or grant that are submitted after the work was performed will not be allowed.
Extra Service Pay: ESP represents overload compensation for effort on contract or grant projects that are clearly in addition to the employee's regular assignment. It is allowable if all of the following conditions are met:
- The work covered by IBS is specified in writing to determine conclusively when work beyond the 1.00 FTE level has occurred. This may be described in appointment letters or other documentation.
- The supplementation amount paid is commensurate with the IBS rate of pay and the amount of additional work performed.
- The total salaries charged to Federal awards including extra service pay are subject to the Standards of Documentation as described in the UF (2 CFR 200.430(i)).
- Faculty typically may charge no more than 0.95 FTE to sponsored projects and must reserve a minimum of 0.05 FTE for non-sponsored activities.
Summer compensation for work performed by faculty members during periods not included in the IBS period will be at a rate not in excess of the IBS. In accordance with federal guidance, no more than 0.95 FTE of summer compensation may be from contracts or grants.
Base salary for purposes other than charges to contracts and grants, such as calculation of University benefits, may be determined in a different manner from the above.