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Office of Research and Project Administration
The National Institutes of Health (NIH) recently announced the FY2010 salary limitation for NIH grants, cooperative agreement awards and contracts. The new salary cap level is $199,700, effective 1/1/10.
Below is the memo outlining the University's 2010 NIH Salary Cap implementation strategy. I have also included the memo as an attachment.
Note that HRMS has been updated to reflect the new cap.
Donna Beyea - x5-8037
January 19, 2010
TO: Deans, Chairs, Directors, NIH Principal Investigators and Administrators
FROM: Gunta J. Liders
Associate Vice President for Research Administration
Office of Research & Project Administration (ORPA)
Douglas W. Wylie
University Controller
Office of Research Accounting and Costing Standards (ORACS)
RE: Revised National Institutes of Health (NIH) Salary Limitation
The purpose of this memo is to provide information on the University’s implementation of the current NIH salary limitation or cap. Effective January 1, 2010 the cap was increased to $199,700. The caps in place for the current fiscal year are summarized as follows:
FY 2009 Awards (linked to Executive Level I)[1]
January 1, 2009 through December 31, 2009 $196,700
January 1, 2010 through December 31, 2010 $199,700
Additional information on the salary limitation, including a list of the salary caps in place since October 1, 1989, can be found in the January 6, 2010 issue of the NIH Guide at: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-041.html
Proposing Salary Costs
Effective immediately, all new and competing proposals should reflect the current salary limitation of $199,700 for faculty whose salary is above the cap. To be consistent with NIH guidance, a statement indicating that actual institutional base salary exceeds the current salary limitation MUST be included in the budget justification. NIH states that if this information is provided and the cap is increased, NIH staff will make necessary adjustments to requested salaries prior to issuing the new or competing award. According to the NIH, however, no adjustments will be made to new or competing Modular Grants. You may use the new cap for non-competing progress reports, but it is unlikely that NIH will award additional funds to cover the increase in the cap.
Implementing and Accounting for the Salary Limitations
In order to minimize the administrative burden associated with implementing and accounting for the various salary caps and to afford Principal Investigators sufficient time to plan for the increased cap, the University will assess the increased salary cap at the beginning of each grant budget year (anniversary date). In other words, the University will assess the applicable salary limitation upon the budget start date and the start date for each continuation year. In those instances where two caps could be assessed in one budget year, the University will assess the lower cap. The University will assess the higher cap level only when the department initiates a change through the salary cap calculation procedure. This will allow departments to utilize the cap levels in a manner that is most beneficial to each individual project. Please use this as an opportunity to review those individuals for which this applies. Reminder: when the new salary cap is charged, a new “Salary Cap Form” will have to be completed. That form can be found in HRMS by those individuals authorized to access personnel forms under “UR Reports and Interfaces,” then “Labor Distribution “ and must be completed on-line. No retroactive cap adjustments will be done unless it is necessary to bring the project into compliance with the NIH salary cap guidelines. The Notice of Award (NOA) issued by ORPA will list the current salary cap that is applicable to the award.
The examples follow:
· If the start date of the award or anniversary date was prior to 1/1/10, the salary cap assessed will be $196,700. This level will be retained until the next anniversary date of the grant. At that time, the salary cap will be assessed at $199,700.
· Any award with a start date or anniversary date of 1/1/10 or after will be assessed the salary cap of $199,700. It is expected that departments will rebudget grant funds from other categories, if necessary. (See section below.)
Re-budgeting
As in previous years, NIH has stated that no funding adjustments will be made to modular awards or to previously established commitment levels for non-competing grants issued with FY 2010 funds. Re-budgeting is allowable provided that funds are available. Departments should consider optimal strategies for re-budgeting, taking into account that PI effort should NOT be reduced to cover the costs of the increased salary limitation. Principal Investigators who are unable to re-budget due to a lack of funds should contact their Department Chair or Dean’s Office for guidance.
Should you have any questions with respect to the University’s implementation of the cap, please do not hesitate to contact Jane Tolbert in ORPA at x5-4210 (jtolbert@orpa.rochester.edu) or Jeff Sullivan at x5-1648 (jpsullivan@finance.rochester.edu) in the Office of Research Accounting and Costing Standards (ORACS).
[1] Federal year (10/01/09-9/30/10) FY 10 awards are defined as competing or non-competing awards made with FY 10 funds.
**************************************************************
Jane Tolbert
Senior Research Administrator
Office of Research & Project Administration
503 Hylan Building
RC
Phone: 585-275-4210
Fax: 585-275-9492
Email: jtolbert@orpa.rochester.edu
[1] Federal year (10/01/09-9/30/10) FY 10 awards are defined as competing or non-competing awards made with FY 10 funds.