The NIH salary cap is $191,300. For budgeting purposes in new NIH grant applications, we suggest that the new salary level be used.

Cost sharing is defined as activities supporting a sponsored program agreement that are not directly paid by the sponsored program. In accordance with Medical Center policy, all new, continuing, and competing applications to sponsoring agencies for support of research, training or related programs are to reflect a level of institutional base salary expense for compensated faculty and staff commensurate with each individual's proposed effort toward the program/project. Effort proposed without commensurate salary will be permitted only under the following conditions:

1. Sponsoring agency or program policy prohibits certain salary support. In those instances, effort will be limited to a maximum of 15%.
   
   
2. Proposed effort is supported from other external funding sources that relate to the program/project (i.e.) Career Development Awards and Center Grants.
   
   
3. Principal Investigator effort on grant applications with a total budget of $75,000 or less. In those cases, the variance between salary and effort will be limited to 10%.
   
   
4. Co-investigator effort when no salary is budgeted. The level of effort will be limited to a maximum of 5% in total for all such arrangements relating to the co-investigator.
   
   
5. NIH awards have salaries capped at $191,300. For example, if an individual performs 10% effort on an award, salary cannot exceed $191,300 (10% X $191,300) on the NIH grant. Salary in excess of $191,300 constitutes cost sharing.

Applications are to indicate the salary commensurate to an individual's level of effort for each year of the project, applying salary increase budgeting factors in accordance with Medical Center policy.

If submitted budgets are to be revised downward as part of the negotiation process with the sponsor, the adjusted salary should remain commensurate with effort.

The administration of sponsored programs is the responsibility of both the academic and administrative departments. Therefore, procedures relating to the cost sharing policy will be performed by the academic departments, the Office of Sponsored Programs Administration and the Finance Department as follows:

The academic departments are responsible for the preparation of sponsored agreement budgets. Since these budgets include committed effort and budgeted salary, both should be in line with institutional policy as described above. In order for the Medical Center to monitor the cost sharing policy, the employees institutional base salary information must accompany the budget, even when the sponsor does not require it. Applications will not be accepted in those instances where:

1. Employee institutional base salary information does not accompany the application.
   
   
2. Salary does not equal effort or an automatic exception does not apply.

All application budgets are reviewed by SPA. SPA will review each budget to ensure compliance with institutional cost sharing policy.

After an award is authorized and the salary charged, the Finance Department will review the awarded budget and actual salary. If this review identifies any possible cost sharing, the academic department will be sent the Confirmation of Committed Effort Form. If the departmental representative determines that there is cost sharing, then that person will identify the amount and the account where cost sharing is occurring. The Financial Analyst will be responsible for confirming that the information is correct. The cost sharing amount will be maintained separately in the time and effort system.

*The Finance Department will review all such individuals to identify the salary exceeding the $191,300 NIH cap. This amount represents cost sharing. The academic department will be responsible for confining this amount on the Confirmation of Committed Effort Form. Thereafter, Finance will maintain this information separately in the effort reporting system.

Documentation

Cost sharing will be documented as follows:

Base Salary

Whenever an application does not require base salary information, this information must accompany the budget submitted to SPA. See attachment A- Base Salary Information Form:

• PDF Format
• Excel 97 Format

Conflation of Committed Effort

As stated above, the Finance Department will review the awarded payroll budget and the accounting records for any possible cost sharing. Based upon this review, the academic departments will be requested to confirm committed effort for certain individuals.

In accordance with the institutional effort reporting procedures, each individual will be required to complete the effort report.

Any questions relating to the cost sharing policy should be directed to Robert Cohen at ext. 3-6796