The Office of Sponsored Programs Accounting (SPA) is responsible for the financial oversight of all grant and contract activity at Tufts University. SPA works with the schools and other central administration offices in the university to ensure compliance with federal/state regulations as well as adherence to university policy.
SPA is responsible for the creation and closeout of grants within the PeopleSoft financial system, and monitors budgets and expenditures of grants & contracts on a regular basis. Additional responsibilities include administering the University Effort Reporting System, billing and collection of receivables and reporting financial grant activity to federal agencies and other sponsors.
Hot Topics in Post Award Research Administration
01/16/14 – The NIH Salary Cap was increased by 1 percent, from $179,700 to $181,500. You can read more about the cap and the Continuting Resolution at NOT-OD-14-043.
NIH announced a revised salary limitation for FY 2014 awards issued on or after January 12, 2014. The executive level II cap has been set at $181,500, an increase of 1 percent from the prior established limitation, for awards issued January 12, 2014 through September 30, 2014. For FY14 awards issued October 1, 2013 through January 11, 2014 the effective salary cap remains at executive level II $179,700.
Please note that since 12/23/2011 (FY 2012) the applicable salary cap has been based on the date when an award was initially issued, not when the actual salary cost is charged. When NIH made this change a Frequently Asked Questions website was created and may be helpful in clarifying the cap(s) applicable to a specific award. You can view the previously published FAQs at http://grants.nih.gov/grants/policy/fy2012_salary_cap_faqs.htm
As a reminder, salary expenses to a sponsored research award from NIH, SAMHSA and AHRQ cannot be paid at a monthly rate that exceeds 1/12th of the maximum annual rate of pay in effect. Since the capped rate in effect as of January 12, 2014 is $181,500, salary paid from awards issued on or after 1/12/14 cannot be paid at a monthly rate that exceeds $15,125. The salary cap of $181,500 is based on a 12-month appointment and if an individual’s appointment is for less than 12
months, the equivalent pro rata salary cap must be used. Some examples are provided below.
Example 1: Award issue date on or after 01/12/14 and PI with 12-month appointment and an institutional base salary of $200,000 devoting 25% effort to an NIH grant.
Charge to NIH grant: $181,500 x 25% effort = $45,375
- Charge to Salary Cap DeptID: ($200,000 x 25% = $50,000) – $45,375 = $4,625
Example 2: Award issue date on or after 01/12/14 and PI with 12-month appointment and an institutional base salary of $200,000 devoting 25% effort to an NIH grant and cost sharing 5% effort .
Charge to NIH grant: $181,500 x 25% effort = $45,375
- Charge to cost sharing DeptID: $181,500 x 5% effort = $9,075
- Charge to Salary Cap DeptID: ($200,000 x 30% = $60,000) – $45,375 – $9,075 = $5,550
Example 3: Award issue date on or after 01/12/14 and PI with 9-month appointment and an institutional base salary of $150,000 (if annualized PI salary would be $200,000), devoting 25% effort during the academic year (AY) and 95% effort for two months during the summer to an NIH grant.
- Prorated cap: $181,500 divided by 12 months x 9 months = NIH cap $136,125
- AY: Charge to NIH grant: $136,125 x 25% effort = $34,031.25
- AY: Charge to Salary Cap DeptID: ($150,000 x 25% = $37,500) – $34,031.25 = $3,468.75
- Prorated monthly cap: $136,125 divided by 9 months = $15,125
- Summer: Charge to NIH grant: $15,125 x 2 months x 95% effort = $28,737.50
- Summer: Charge to Salary Cap DeptID: ($150,000 divided by 9 months x 2 months x 95% effort = $31,666.67) – $28,737.50 = $2,929.17 (if allowed by department)
For more information log onto the NIH websites below. If you have award-specific salary cap questions, please contact your SPA Post Award Financial Specialist. The Office of Research Administration is also available to answer questions you may have regarding the new cap.
12/26/13 – The Office of Management and Budget finalized guidance that will supersede and streamline requirements from eight OMB Circulars – A-21, A87, A-89, A-102, A-110, A-122, A-133 and parts of A-50. OMB hopes to provide clarity and reduce administrative burden with this new “omni circular”. The guidance was published in the Federal Register on 12/26/13 and the federal agencies have been given one year, until December 2014, to update their policies accordingly. The regulations will be effective for non-federal entities, like Tufts, when the agency-specific guidance is finalized. We are in the process of reviewing the 750+ page document and will share more information with the Tufts research community as it becomes available. A copy of the final guidance document can be found here.
11/18/13 – A new version of the Proposal & Award Policies & Procedures Guide (PAPPG), (NSF 14-1) has been issued by the National Science Foundation for proposals submitted, or due, on or after February 24, 2014. A summary is provided at the beginning of both the Grant Proposal Guide and the Award & Administration Guide to assist with identifying the changes in this version. While this version of the PAPPG becomes effective on February 24, 2014, in the interim, the guidelines contained in the current PAPPG (NSF 13-1) continue to apply.
10/26/13 – NIH announced a revised version of their Grants Policy Statement (NIHGPS), effective for all NIH grants and cooperative agreements with budget periods beginning on or after October 1, 2013. A summary of significant changes was also released, highlighting updates since the October 1, 2012 GPS was issued. If you have any questions about the PPAG or NIHGPS, or are unsure which version applies to your award, please contact your SPA or ORA representative.
09/26/13 - On October 1, 2013, NIH began transitioning all new awards (funded with federal fiscal year 2014 (FFY14) funds) to an “award-by-award” format for reimbursement requests and expenditure reporting. While NIH originally announced that continuing awards would also begin to be issued in this format, it later clarified that the transition will begin on October 1, 2014 for all continuation awards funded with FFY15 funds.
While we are still awaiting further clarification from DHHS, SPA is actively preparing for the transition over the next year. The effects of the new requirements, impacting departments, PIs and SPA, are outlined below.
- Adherence to carryover requirements: The notice restated NIH’s existing policy requiring awardees to justify any carryover that is greater than 25% of the total authorized amount for the current budget period. If the GMO determines that some or all of the unobligated funds are not necessary to complete the project, the GMO may restrict the grantee’s authority to automatically carry over unobligated balances in the future, use the balance to reduce or offset NIH funding for a subsequent budget period, or use a combination of these actions. Departments and PIs should continue to monitor spending to avoid any loss of funding.
- New reimbursement request procedure: Any new competitive awards issued between 10/1/13 – 12/31/14 will be awarded in the award-by-award format; the additional burden will be only in SPA, as we are required to request reimbursements and report expenditures via two processes effective 10/1/13.
- Additional financial reporting and closeouts: During the period of 10/1/14 – 12/31/15 continuation awards will be issued in the new format. In order to transition awards in the middle of their life cycle to this new payment method, the life cycle will be broken into two shorter segments. SPA will work with departments and PIs to submit final financial reports and closeout the initial segment. Internal allocations (p-card, PAFs, Marketplace, etc.) will also require updating by the departments and PIs.
The NIH Notice announcing these changes and FAQs related to it can be accessed at http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-120.html and http://grants.nih.gov/grants/payment/faqs.htm. Further guidance will be provided over the next few months for PIs and department administrators to ensure timely reporting and that loss of federal funding is not a risk.