The National Science Foundation (NSF) has a regulation stated in its Proposal & Award Policies & Procedures Guide (PAPPG) that limits the amount of compensation that "senior personnel" can propose on NSF awards.
The relevant portion of the regulation is included here with key terms in bold:
"….NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year....It is the organization's responsibility to define and consistently apply the term "year," and to specify this definition in the budget justification. This limit includes salary compensation received from all NSF-funded grants....If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget....a grantee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two-month salary policy. No prior approval from NSF is necessary unless the rebudgeting would cause the objectives or scope of the project to change. NSF prior approval is necessary if the objectives or scope of the project change.
The terms in bold above need to be defined to understand this regulation.
Salary: per 2 CFR 200.430 compensation - personal services, salary is an allowable cost at the institutional base salary (IBS) rate.
Senior personnel: NSF’s definition of senior personnel: "…individual(s) designated by the proposer, and approved by NSF, who will be responsible for the scientific or technical direction of the project.
These individuals are listed by name on the NSF Award. The typical NSF format for how these senior personnel appear is below and often found at the beginning of the award document. Here are two current examples:
Year: NSF regulations state that the organization can define the year. NIU has defined this as our fiscal year, which runs from July 1 through June 30.
Organization/grantee: this is NIU, as it is the grantee of the NSF award.
SPA’s interpretation of this NSF regulation is that any senior personnel listed on an NSF Award cannot propose more than two months of their IBS on all NSF awards in an NIU fiscal year. This two-month limitation can only be exceeded under certain circumstances.
In the proposal: if, at the time of proposal preparation, it is known that senior personnel will exceed the two-month limit, include language in the proposal that identifies that the limit will be exceeded, and request approval as part of the submission. SPA encourages the below language:
"In accordance with section II.D.2.f(i)(a) of the PAPPG, sponsor approval is required if upon issuance of this Award, the senior personnel will exceed the two-month limitation for all effort on NSF awards in the NIU’s fiscal year. For this proposal submission, we expect that {name senior personnel} will expend {xx} months on this award and that, combined with existing NSF awards, will put them over the two-month limit.
If the proposal is fully funded, sponsor approval is considered to have been obtained.
Post-award rebudgeting: per NSF regulations, if the proposal does not have the senior personnel exceeding the two-month rule, but due to rebudgeting the effort exceeds two months, NIU does not need to obtain NSF approval. Instead, the internal rebudget request simply needs to document that the effort has now exceed the two-month limit.
Submit your rebudget request to your contracts (grants and contract) associate (GCA) via the Rebudget Form.
Pre-award and Proposals
asosp@niu.edu
Post-award and Award Management
grantsfiscal@niu.edu
InfoEd Questions
erahelp@niu.edu