Excess Compensation in Sponsored Programs Policy

1. Purpose of Policy

The purpose of this policy is to provide guidelines for complying with the federal government through Code of Federal Regulations Title 2: Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200.)

2. Stakeholders Most Impacted by the Policy

This policy applies to Principal Investigators engaged in research, projects, activities conducted under the auspices of Western Michigan University whether the activities are conducted on or off campus.

3. Key Definitions

3.1 Institutional Base Salary (IBS):  IBS is defined as the annual compensation pay by an Institution of Higher Education (IHE) for an individual’s appointment whether that individual’s time is spent on research, instruction, administration, or other activities. IBS excludes any income that an individual earns outside of duties performed for the IHE.

4. Full Policy Details 

4.1. 2 CFR 200.430 Office of Management and Budget: Uniform GuidanceSection 200.430 Charges for work performed on Federal award by faculty members during the academic year are allowable at the IBS rate.

4.2. Salary basis. Section 240.430 (h) indicates faculty’s compensation cannot be more than their IBS during the faculty member’s specified contract period.    .  Unless there is prior approval by the Federal awarding agency, charges of faculty member’s salary to a federal award must not exceed the proportionate share of the IBS for the period during which the faculty member worked on the award.

4.3. Intra-IHE consulting by faculty is assumed to be undertaken as an IHE obligation requiring no compensation in addition to IBS. 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 [their] regular responsibilities, any charges for such work representing additional compensation above IBS are allowable provided that such consulting arrangements are specifically provided for in the agreement or approved in writing by the sponsoring agency.”

4.4. Periods outside the academic year. Except as otherwise specified for teaching activity in 4.1.4 below, charges for work performed by faculty members on federal awards during periods not included in the base salary period (e.g., summer sessions) will be at a rate not in excess of the IBS.

4.5 Charges for teaching activities performed by faculty members on federal awards during periods not included in IBS period will be based on the normal written policy of the IHE governing compensation to faculty members for teaching assignment during such periods.  In the case of WMU, the written policy would be the AAUP contract.

4.6. Part time faculty. Charges for work performed on federal awards by part-time faculty members 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. They devote one-half of their remaining time to a sponsored agreement. Thus, additional compensation, chargeable by the institution to the agreement, would be one-half of $5,000, or $2,500.

5. Accountability 

5.1. Failure to adhere to these Federal regulations in connection with a specific sponsored project may result in the withholding of new awards.

5.2. Any unallowable costs as a result of an audit will be charged back to the department.

5.3. Failure to follow this Policy and any associated procedures may subject WMU employees to disciplinary action, up to and including dismissal from employment by the University consistent with applicable procedures and Collective Bargaining Agreements.

6. Related Procedures and Guidelines

Excess Compensation In Sponsored Programs Procedure 

WMU AAUP Contract

OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Circular 2 CFR 200

Office of Management and Budget: Uniform Guidance 2 CFR 200.430

7. Additional Information 

Code of Federal Regulations Title 2: Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.