Salary Costs
The personnel section of the proposed budget includes information about the role and salary of each individual required to complete the sponsored project. Only Drexel employees should be listed as personnel. Non-Drexel employees are listed in the appropriate consultant or subaward budget section.
Salary rates for personnel employed on sponsored projects should be consistent with sponsor guidelines as well as rates paid from University-administered funds. Salaries charged to sponsored projects should coincide with the period of effort spent on the project. Salary for faculty, technicians, research associates, research assistants, postdoctoral associates and other technical or programmatic personnel required to meet the goals of the project are allowed as direct costs.
Compensation and new job classifications must conform to Drexel Human Resources classifications. Please discuss with your department administrator or Drexel Human Resources Business Partner.
Federal Compensation Guidance
Federal Compensation Guidance Federal compensation guidance is outlined in the Code of Federal Regulations: 2 CFR 200.430 [PDF]. The federal Consolidated Appropriations Act [PDF] limits the rate at which salaries are paid under sponsored research awards funded by certain agencies of the Department of Health & Human Services (HHS). The cap, which is tied to levels of the Federal Executive Pay scale specified in the Consolidated Appropriations Act, establishes a maximum annual rate of pay at which an individual can be compensated for full-time work committed over a 12-month period.
Sample of HHS agencies that apply a cap to the salary budgeted and charged as an allowable expense
The National Science Foundation (NSF) regards research as a standard responsibility of faculty and therefore limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with2 CFR 200, Subpart E [PDF], including 2 CFR 200.430(i) [PDF].
Salary caps and limitations vary from sponsor to sponsor. Refer to sponsor guidelines to determine the salary caps and limitations in effect at the time of the proposal submission.
Key Personnel
Key personnel are typically the program/project director, principal investigator or other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way. They are always identified by name, title and role on the project regardless of whether or not they request salary or compensation.
The proposal budget should accurately reflect the amount of the effort that key personnel are committing to the project. Although A-21 was retired Dec. 25, 2014, Memorandum M-01-06 is located in 2 CFR 200.306(k), where it references institutes of higher education. OMB 01-06 describes the specific requirements for key personnel. Should you have questions, please contact the sponsoring agency.
Other Project Personnel
Personnel in other positions are identified by name and role. This includes postdoctoral associates, other professionals, research assistants and students. When an individual cannot be identified at the time of submission or will be hired to fill the proposed role at a later time, to-be-announced (TBA) can be used in place of the name, along with the role. TBA cannot be used for key personnel. The proposal budget should accurately reflect the amount of effort personnel will commit to the project.
Administrative and Clerical
Federal regulations state that clerical and administrative salaries should be treated as indirect costs. However, it may be appropriate to charge them as direct costs if certain general criteria are met. Per 2 CFR 200.413 Direct Costs [PDF], the following are required to qualify the costs:
- Administrative or clerical services are integral to the project or activity;
- Individuals involved must be specifically identified with the project or activity;
- Such costs are explicitly included in the proposed budget or have the prior approval of the sponsoring agency; and
- The costs are not also recovered as indirect costs.
These requirements do not apply to salaries for technical personnel, graduate students, postdoctoral associates and other project personnel.