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1. Purpose of Policy

The purpose of this policy is to provide guidelines for complying with the federal requirements in Title 2 of the Code of Federal Regulations (2 CFR Part 200) as applicable to summer salary funded by grants, contracts and other sponsored programs.

2. Stakeholders Most Impacted by the Policy 

This policy applies to all faculty engaged in research, projects, activities conducted under the auspices of Western ¾ÅÒ»Â鶹ÖÆƬ³§ University whether the activities are conducted on or off campus regardless of the funding source.

3. Key Definitions 

3.1 Institutional Base Salary (IBS):

The amount determined by the University to compensate an individual for their primary professional obligation based on grade, title, and experience.  IBS is based on full-time equivalents and will be adjusted proportionately for part-time effort.

3.2 Salary Cap:

Limitation imposed by the federal government on the amount of salary that may be charged to federally funded grants or contracts.

4. Full Policy Details 

Charges to grants and contracts for summer research activities must be consistent with the level of effort devoted to each grant or contract during the period identified and with the funding provided.  This effort must be subsequently confirmed within ecrt system (i.e., Payroll Confirmation) (see Section 6 Related Procedures and Guidelines).

Release time during the academic year for research activities on grants, contracts, and other sponsored programs cannot fulfill one’s summer commitment.

4.1 Summer Salary Limitations:

• 4.1.1. Faculty are limited to 95% of the summer maximum earnings from all activities (teaching, research, and service) of the university. Maximum earning are 50% of IBS. The remaining 5% is reserved for such activities as service or administrative duties, development of grant proposals, or time off for personal activities.
• 4.1.2. A faculty member who wishes to devote more than 95% effort to summer work must petition the Office of the Vice President for Research and Innovation for permission, and provide a full justification of the additional effort and salary and a detailed timeline of the work proposed.  Any person petitioning ORI to charge more than 95% effort in the summer months must confirm in their request that vacation is not permitted.
• 4.1.3. All effort devoted and corresponding salary charged to a sponsored project(s) must be in compliance with sponsor and university policies
• 4.1.4. Committed effort on a sponsored project should be devoted exclusively to the activity supported by that sponsored project. Salary charges must align on a monthly basis to the effort provided to the grant or contract funded by an external organization (i.e., sponsored project).
• 4.1.5. Time committed to other activities performed during the summer months, e.g., any general administrative or academic activities or writing new proposals, may not be charged to a grant or contract funded by an external organization. 
• 4.1.6. Additional agency award requirements may be applicable and must be met.

4.2 Agency Specific Restrictions:

• 4.2.1. National Science Foundation (NSF) salary for all NSF-funded projects is limited to no more than 2/8^th of regular annual academic salary per year. This two month limit applies to all salary charged to NSF salary – both allowable academic year salary plus summer salary. This includes NSF funds that WMU receives through sub-award arrangement.
• 4.2.2. Salary Cap Restrictions
• National Institutes of Health (NIH)salary cap reduces the charges to the capped amount. Amounts over the cap may be charged to the PIs discretionary funds. Salary caps for proposal submission are limited to Executive Level II as defined by NIH and are subject to change each year.
• 4.2.3. Other sponsors may have restrictions on summer salary so faculty should consult their award terms and conditions prior to committing summer month effort. Any questions regarding sponsor terms or conditions should be addressed to ORI.

4.3 Processing Summer Pay on Grants and Contracts:

So WMU may monitor compliance with this Policy, Faculty working on sponsored projects must complete additional forms to request summer pay.  These forms must be completed prior to processing any summer pay on grants or research contracts. Additional information regarding summer salary charged to grant and contracts may be found at http://wmich.edu/grantscontracts/forms

5. Accountability 

Failure to follow this Policy and associated procedures may also subject WMU employees to disciplinary action, up to and including dismissal from employment by the University.

6. Related Procedures and Guidelines 

Summer Salary on Grants and Contracts Procedure 

Periods outside the academic year.Except as otherwise specified for teaching activity in (h) (5) (ii) below, charges for work performed by faculty members on federal awards during periods not included in the base salary period will be at a rate not in excess of the IBS. 

(h)(5)(ii) Charges for teaching activities performed by faculty members on federal awards during periods not included in IBS period will be based on the normal written policy of the IHE governing compensation to faculty members for teaching assignment during such periods.

Reasonableness. Compensation for employees engaged in work on Federal awards will be considered reasonable to the extent that it is consistent with that paid for similar work in other activities of the non-federal entity.

Allowability of costs. Be consistent with the policies and procedures that apply uniformly to both federally-finances and other activities of the non-federal entity.

7. Additional Information

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