Background
The university generally expects that faculty participation in externally funded activities will be accommodated through release time from academic year duties or summer compensation. Faculty regular appointments inherently include responsibilities for research, instruction, and service, and therefore do not typically warrant extra compensation for work performed within those roles.
To ensure compliance with institutional policy and federal regulations, charges to grants must align with university policy and procedures. University policy states that faculty should normally not be employed beyond full-time employment (i.e., extra compensation) from the state of Illinois or other university funds. Any extra compensation should be under extraordinary circumstances and must be for a specific operational need and limited in duration clearly beyond the employee's regular appointment.
Intra-institutional consulting is a situation when individuals within the same institution provide expert advice or services to support grant-related activities and typically involves collaboration across departments or divisions to strengthen a grant funded project. Federal regulations governing grants—and by extension, the state of Illinois guidelines via GATA require that intra-institutional consulting should be undertaken as part of a faculty member's institutional responsibilities (i.e., research, instruction and service) requiring no compensation in addition to institutional base salary.
Intra-institutional consulting does not apply to principal investigator(s), co-principal investigators and other key personnel because they cannot be consultants to their own work. Thus, it would not be appropriate for individuals holding these positions on grants to receive extra compensation from their own projects.
For non-key personnel, extra compensation for intra-institutional consulting is only appropriate in rare circumstances (i.e., requests should not be made on a regular or recurring basis). In these unusual circumstances, the following criteria must be met.
- The work is clearly outside of the individual's regular appointment duties covered by their institutional base salary (IBS).
- The written definition of work covered by IBS is provided and is specific enough to determine conclusively when work beyond that level has occurred.
- An explicit and strong justification is provided regarding why release time or summer compensation cannot accommodate the work.
- The compensation is reasonable and consistent with NIU policies and is at a rate comparable for similar work within the university.
- The work and extra compensation are properly documented and included in NIU's time and effort system.
- The work and extra compensation are approved in advance by the sponsor.
This guidance outlines the internal review and approval procedure for extra compensation on grants for those rare and unusual circumstances in which the criteria for intra-university consulting by non-key personnel are met.
Applicability
- Consistent with university policy, this procedure uses the term faculty but applies to faculty and all administrators in Supportive Professional Staff (SPS) with faculty rank roles.
- This guidance does not apply to summer salary payments for faculty on less than 12-month contracts. Such summer compensation should follow relevant university policy and procedures.
General Budgeting Expectations
Extra compensation will be:
- Included and clearly identified as extra compensation (above 100% salary) under the personnel: salaries and wages section of the budget and in the accompanying budget justification.
- Subject to standard budgeting practices, including the inclusion of fringe benefit costs.
- Compliant with Human Resources and Academic Affairs policies.
Procedures
Pre-award
Principal investigators anticipating a need to request extra compensation for a non-key personnel faculty member as part of a grant project must work with the faculty member to obtain approval via the Faculty Extra Compensation Approval Grants form before the extra compensation is written into the proposal budget. Approvers will carefully evaluate all criteria when considering the request. Their endorsement of the extra compensation indicates that all criteria are fully met and that there is an unusual need that cannot be accommodated by release time, by summer compensation, by a different person, and that the need is short-term and limited in duration.
The faculty member receiving extra compensation is responsible for initiating the form. The approval process should begin at least six weeks (about a month and a half) before the proposal deadline to allow all approvers time to review the request. Approvers include the faculty member receiving the extra compensation, their department chair, dean (or equivalent positions), principal investigator, associate vice president for research and vice provost for faculty affairs.
SPA will not approve or submit any proposals that budget for extra compensation without these approvals. A copy of the signed Faculty Extra Compensation Approval Grants form will be retained in the SPA grant record and may be subject to audit.
If the extra compensation is approved, SPA will explain the payment in the budget justification as:
- Funds are budgeted for X% of extra compensation salary above XXXX's institutional base pay in accordance with 2 CFR §200.430(h)(4), and NIU Policies and Procedures. XXXX has been determined to be a non-key personnel on this project and it has been determined that their work and services for this project of XXXXX is an unusual circumstance that cannot be accommodated by release time or summer compensation, falls outside the scope of their university appointment, and would not be expected to recur in the future. The work is across department lines or involves a separate or remote location in the following ways: XXXXXX.
- The internal budget will also clearly label the salary as extra compensation (above 100% of institutional base salary).
- Note: An employee's joint appointment (e.g., with another NIU department or center), affiliation relationship (e.g., at a research or service center, or a national lab), a component of their research, teaching or service portfolio (e.g., their own lab), or NIU location (e.g., Naperville campus) would not be considered across department lines or separate/remote location.
The extra compensation checkbox on the InfoEd proposal summary review tab will be checked to flag budgets including extra compensation.
Post Award
- If extra compensation presented in the proposal follows the pre-award procedure and the proposal is approved by the sponsor without removing the extra compensation, SPA will consider it approved. Principal investigators should proceed to work with their department to submit the extra compensation for the individual following HRS additional pay procedures.
- Extra compensation payments to grants must use HRS Earn Code E30 to capture the payments for time and effort reporting and to meet uniform guidance standards of documentation requirements.
- If extra compensation was not clearly presented in the proposal or did not follow the pre-award procedure the grants and contracts associate will require completion of the Faculty Extra Compensation Approval Grants form and prior written approval from the sponsor before authorizing extra compensation payments from the award. Completion of this form and sponsor approval is also required for any increase in previously approved extra compensation or for different individuals to receive extra compensation. Obtaining sponsor approval may take several months and therefore, could delay project work.
Initiating Post Award Prior Sponsor Approval
- The principal investigator will direct the faculty member receiving the extra compensation to initiate approval for the extra compensation via the Faculty Extra Compensation Approval Grants form.
- If the extra compensation is approved internally, the completed Faculty Extra Compensation Approval Grants form and accompanying sponsor request will be submitted to the grants and contracts associate for final review. The grants and contracts associate will confirm that sufficient funds exist in the budget and obtain SPA director signature on the request and submit the request for sponsor review.
- If the sponsor approves the request, the grants and contracts associate will issue a revised SPA notice of award (NOA) indicating agency approval. The principal investigator may then work with their department to submit the extra compensation for the individual following HRS additional pay procedures.