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Effective Date: |
10/1/11 |
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Version # / Revision Date: |
2/16/22 |
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Responsible Office(s): |
Office of the Vice President for Research and Office of Sponsored Projects |
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Approval: |
Office of the Vice President for Research |
Contents
➢ Completing the Proposal Stage NIH Salary Cap Worksheet
➢ Entering NIH Salary Cap Information into Coeus Budget
➢ Distributing the “Over the NIH Cap” Cost Share
➢ Answering Yes/No Questions - Question 0B18
➢ Uploading the NIH Cap Worksheet in the Narrative / Attachment Section
➢ Including the Applicable Statement in the Budget Justification
Overview
This document outlines the procedure for correctly completing the NIH Salary Cap Worksheet, entering NIH Cap Salary information into the Coeus Budget and distributing the amount over the NIH Cap Cost Share at the Proposal Stage. NIH Cap is a limitation placed on the salary rate that can be directly charged to contracts, grants and cooperative agreements funded by the National Institutes of Health (NIH), the Substance Abuse and Mental Health Services Administration (SAMHSA) and Agency for Healthcare Research and Quality (AHRQ) awards.
The Department of Defense and Full-year Continuing Appropriations Act of 2011 (Public Law 112-10) continues to restrict the amount of direct salary of an individual under an NIH/SAMHSA/AHRQ grant, cooperative agreement or applicable contract to Executive Level I of the Federal Executive Pay Scale. Effective January 2, 2022, the Executive Level II salary level is set at $203,700 (per NIH Guide Notice NOT-OD-22-076 issued on 02/10/2022). The appropriate salary cap rate must be applied to competing and non-competing awards based upon the federal fiscal year (FFY) (10/XX– 09/YY) in which the Notice of Grant Award was issued.
Direct salary is exclusive of fringe benefits and facilities and administrative (F&A) expenses, also referred to as indirect costs. The appropriate salary cap rate must be applied to competing and non-competing awards based upon the award date on the Notice of Grant Award. Also, the cap is not on the number of dollars that can be charged to an NIH grant.
Rather, the cap is on the monthly pay rate that can be charged to an NIH grant. For example, the current NIH salary cap is $203,700, which is a maximum of $16,975 per month.
Procedure
➢ Completing the Proposal Stage NIH Salary Cap Worksheet
The NIH Salary Cap Worksheet was developed to aid departments in calculating the appropriate % Charged to the NIH grant / cooperative agreement. This worksheet should be completed for any individual over the NIH Salary Cap.
There are two different worksheets contained in this excel workbook; the Proposal Stage and the Award Stage. They slightly differ to capture the necessary information required at each grant stage. The Proposal Stage worksheet is designed to capture the percentage charged for salary over the cap for each Fiscal Year of the project. It also includes a column to capture the appropriate percentage charged when effort changes within a FY.
To Complete the Proposal Stage Worksheet:
1. Enter the Individual’s Name, Current Salary, and Escalation Rate in the top portion of the Spreadsheet – e.g.:
2. The Faculty AY Salary will calculate for each fiscal Year available in the Spreadsheet based on the information entered in the previous step – e.g.:
3. The Spreadsheet is divided into three Sections based on Appointment Type: 12 Month Appointment, 10 Month
Academic Appointment and Summer Salary, 9 Month Academic Appointment and Summer Salary.
4. Navigate to the appropriate section of the Spreadsheet based on the Appointment Type of the Individual and enter their % effort on the project for each Brown Fiscal Year of the Project.
It is important to keep in mind that in most cases the project periods will not correspond to the Brown Fiscal Years (07/01/XXXX – 06/30/XXXX).
E.g.: If the Project Period is 09/01/2011 – 08/31/201, that encompasses the following Brown Fiscal Years:
Project Period Brown Fiscal Years
09/01/2011 – 08/31/2012 FY 2012 & FY 2013
09/01/2012 – 08/31/2013 FY 2013 & FY 2014
09/01/2013 – 08/31/2014 FY 2014 & FY 2015
So for example, the Spreadsheets would be completed as follows if the individual had a 9 Month Academic Appointment, their effort was 10% during the Academic Year and 10% during the Summer Months and the Project Period was: 09/01/2011 – 08/31/2014:
5. Save your Worksheet.
A separate worksheet must be completed for each individual whose salary is over the NIH Cap.
➢ Entering NIH Salary Cap Information into Coeus Budget
The NIH Salary Cap Information for individuals is added in the Coeus Budget by using Personnel Line Items (or Personnel
Cost Elements) that describe who will be paid out of the award if the proposal is funded. Keep in mind that the Budget
Persons Window must be completed first, before you can add Personnel to the budget.
To enter the NIH Cap Salary information into Coeus Budget:
1. Complete the Budget Persons Window as you normally would. For the individuals whose Salary is over the NIH Cap, enter their actual salary information in the Calc. Base field (NOT the NIH Cap of $203,700).
2. Add the appropriate Personnel Line Item (Personnel Cost Element). Following are the Personnel Line Items available in Coeus for NIH Cap Salary entry:
▪ Faculty Salary – NIH CAP – Academic Year
▪ Faculty Salary – NIH CAP – Summer
▪ Faculty Salary – NIH CAP – Non Regular Research
You select the appropriate Line Item based on the Individual’s Appointment Type and the period that they will be working.
3. Add the individual into the Personnel Line Item. Adjust the Start and End Dates in the Personnel Budget Details Window to reflect the correct period. Also, if project period crosses Brown Fiscal Years make sure to split project period into the appropriate Brown Fiscal Years (this step is necessary because the salary for Faculty and Staff is set to inflate every July 1st).
Example:
4. In the %Charged field enter the “%effort distribution to the NIH account” number calculated in the NIH Cap
Worksheet for the appropriate Fiscal Year. In the %Effort field enter their %Effort on the Project.
Example:
Personnel Budget Details Window
NIH Salary Cap Worksheet
5. After you “Generate All Periods” of the Budget, you will need to go into each NIH Cap Personnel line item and manually adjust the % Charged for each Brown Fiscal Year based on your NIH Cap Worksheet.
➢ Distributing the “Over the NIH Cap” Cost Share
Since in the NIH Cap Personnel Line Items the % Charged and % Effort amounts are different, Cost Share is generated. The Cost Share amount that is generate represents the Salary amount being Cost Shared as well as the associated Fringe Benefits and the Indirect Costs.
All Brown University’s Cost-Sharing on proposals needs to be recorded in Coeus Budget and Distributed accordingly to the appropriate account(s).
To distribute the amount “Over the NIH Cap” Cost Share:
1. While in the Budget Section, select Edit → Cost Sharing Distribution from the menu bar to open the Modify
Proposal Cost Sharing Window:
The Total Cost Sharing field displays the full amount that needs to be distributed to accounts by period; in this example, the “Over the NIH Cap” Salary and associated Fringe Benefits and F&A. (Keep in mind, that in this window, for example, Fiscal Year 2012 means Project Period 1)
Cost Sharing dollar amounts are entered in the Amount field for each Project Period (Fiscal Year) and you must enter an account that will be responsible for the Cost Share amount in the Source Account field for each Project Period (Fiscal Year).
2. For THOSE amounts that represent the “Over the NIH Cap” Salary Cost Share (plus associated Fringe Benefits and F&A), you MUST enter “NIHCAP” in the Source Account field for each Project Period (Fiscal Year) [An actual account number does NOT get assigned to this type of Cost Share)
3. Click the [Ok] button to close out of this Modify Proposal Cost Sharing Window.
➢ Answering Yes/No Questions - Question 0B18
Since the proposal includes salaries that are over the cap, Brown University Question 0B18 (If applicable, are proposed salaries over the cap? If yes, include NIH Salary Cap Worksheet with submission.) must be answered “YES”.
To answer the Yes/No Question:
1. From the Proposal Details Section, navigate to the Yes/No Question Section in Coues by selecting Edit → Yes
No Questions from the menu bar.
2. In the Proposal Question Window, scroll down to question 0B18 and answer the question “YES” by selecting the
“YES” radio button.
➢ Uploading the NIH Cap Worksheet in the Narrative / Attachment Section
Finally, the NIH Salary Cap Worksheet that you have completed must be uploaded in the Narrative Section of Coeus.
To upload the Worksheet:
1. From the Proposal Details Section, navigate to the Narrative Section in Coeus by selecting Edit → Narrative
from the menu bar.
2. In the Narrative for Proposal Window, select Edit → Add to open the Add Module Window.
3. In the Add Module Window, select the Narrative Type by clicking on the Arrow to the right of the Narrative
Type field. For the Worksheet, select NIH Salary Cap Worksheet Narrative Type.
4. To upload the worksheet to the Narrative Module, click the [Upload] button in the Add Module Window to navigate to your computer files and upload the desired attachment. Select the desired file on your computer or network and click the [Open] button. The document name will appear in the File Name field.
*Note - the NIH Salary Cap Worksheet MUST be uploaded for each individual whose salary is over the NIH Cap.
5. Set the Status of your Attachment to either Complete or Incomplete in the Status field. Click on the [OK] button to exit out of the Add Module window and return to the Narrative for Proposal Section.
6. Optional – Since the worksheet has salary information, you can limit the access to this attachments, if need be, to other individuals assigned to the proposal. This is done by setting restrictions on the NIH Salary Cap Worksheet Narrative Type. (Assigning Narrative Attachment Rights to the Users listed at the bottom of the Add Module window for the document uploaded.)
When uploading Narrative Attachments one has the ability to assign the following Rights to Users:
➢ Read – able to view the attachment only
➢ Modify – able to view and edit the attachment (Default Selection)
➢ None – do not have the rights to view or edit the attachment
➢ Including the Applicable Statement in the Budget Justification
Since the proposal includes salaries that are over the cap, you must include an explanation in the Budget Justification.
Example: “Personnel X will devote X Percent of a 1.0 FTE appointment with Brown University toward the goals of this project. His/her current Institutional Base Salary exceeds the NIH cap. Brown University’s Institutional policy is to request and charge all NIH sponsored projects at the NIH salary cap for those salaries that are in excess of the cap. Therefore, this application requests salary at the current NIH salary cap. The salary over the NIH salary cap will be accounted for in accordance with federal policy.”
Contacts
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Subject |
Contact |
Phone |
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Proposal Stage- Policy and Procedure Questions |
401-863-2777 |
Revision History
• Version 1 - New procedure – 10/18/11
The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.