U.S. ATLAS HL-LHC Upgrade Level 2 and Deputies-NSF only Management Mailing List

[Michael Tuts <tuts AT pmtuts.net>]

Hi NSF L2 and Deputies,

 

I have cut and pasted below a message that we (Columbia) received from our EVP for finance. They have reversed the policy that allowed us to pay for standing army costs on government grants (in our case retroactive to June 17 when the OMB changed the guidelines) to say you now need to exhaust other non-government funding sources first before you can support these standing army costs on grants. We bring this up with you because in their “review, in conjunction with that of higher education associations, suggests that this requires using faculty discretionary funds and departmental and school resources before being able to charge pay continuation costs to sponsored awards”. So rather than expose themselves to having to use other funds first, they simply said they will no longer allow any such charges on the grant. So maybe the same thing is happening at your institution? You should advise you CAMs and institutional contacts to check what their institution is doing in terms of allowable charges on the subawards.

 

I have notified the NSF and am seeking any guidance they might have.

 

Your PO

 

From Columbia EVP:

Dear All,

 

I write with an important, time-sensitive update concerning charging salary to sponsored projects: As of June 17, all salaries and benefits for individuals on pay continuity (not able to perform the responsibilities of their roles because of COVID-19 disruption) may no longer be charged to sponsored awards.  There is no change for individuals who are able to work on sponsored projects, whether they work remotely or on campus.

 

1.           Change in Pay Continuity Policy

Since March 2020, in accordance with federal guidance and University interim policy on pay continuity, principal investigators have been able to charge salaries to grants for individuals who were unable to fulfill their job functions remotely because of the public health emergency.  During this time, principal investigators have been expected to monitor the impact of COVID-19 on their projects and to document this appropriately, including whether team members have been on pay continuity.  For reasons explained in the Background section below, our pay continuity policy is changing. 

 

Effective June 17, 2020 all salaries and benefits for individuals on pay continuity (not able to perform the responsibilities of their roles because of COVID-19 disruption) may no longer be charged to sponsored awards and must be transferred to a non-sponsored school source.  This requirement applies to all sponsored projects, regardless of the funder.  In light of the University’s year-end close, any salary charges relating to the period between June 17 and June 30 that require adjustment must be transferred no later than July 13, 2020. 

 

With the ongoing research ramp-up, the impact to your teams should be limited. Individuals who are working on sponsored projects, either remotely or on campus, can be charged to sponsored projects as usual.  Our current Stage 1 ramp-up prioritizes those who cannot work remotely and takes into account grant deliverables and other exigencies.  In addition, approved leaves pursuant to University policy may be charged to sponsored projects in the usual manner.  As of June 17, however, salary transfers are required for any individual on pay continuity – that is, any individual whose effort on sponsored projects is significantly reduced because their job functions require their presence on campus, but their ability to be on campus is materially constrained.  In any such case, an amount of salary commensurate with the individual’s reduced activity must be transferred from the sponsored project(s) to a non-sponsored school source. 

 

Finally, the University is planning the transition to Stage 2 of the research ramp-up in the very near future. This will afford for the return of more researchers to campus, subject to public health requirements, and thus further decrease the need for pay continuity.

 

2.           Immediate Actions for Principal Investigators and Administrators

At this time, and as part of the usual quarterly monitoring of effort and expenditures, principal investigators must carefully review the effort of their team members and consult with them as needed to assess whether any salary transfers are required. In addition to the usual review, Principal Investigators and administrators must work together to identify any individuals who, effective June 17, were unable to fulfill their job function or whose effort is significantly reduced, and make any needed salary transfers by July 13.

 

The Controller’s Office within Finance will work with each of the schools to establish a designated school unrestricted project by July 6 and specific instructions for moving salaries to that project. Departmental totals will be summarized for chair review and approval.  To assist, the University will provide supplementary funding for appropriate expenses for the period June 17 to June 30, 2020.  Schools will follow with additional guidance for the next reporting period. We would expect any adjustment to salaries charged to sponsored projects to be reasonable and consistent with the monitoring of pay continuity since the inception of the pandemic, referenced above.

We are working on revised policies concerning pay continuity and leave management, and will communicate those as soon as we can.

 

3.           Background

In March 2020, when the University ramped down research in response to the public health emergency, we were able to utilize an interim federal policy authorizing the limited use of federal funds to support personnel who could not perform their job functions due to COVID-19 disruption.   This flexibility allowed principal investigators to use sponsored funds to pay project personnel in accordance with our institutional policy of pay continuation for individuals who were unable to work due to lack of access to facilities or similar reasons.   

On June 18, the federal government rescinded the interim policy, extending the salary continuation authority to September 30, 2020, but adding a significant restriction.  Under these revised rules Columbia is required “to exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (such as rent renegotiations) during this pandemic period in order to preserve Federal funds for the ramp-up effort.”   Our review, in conjunction with that of higher education associations, suggests that this requires using faculty discretionary funds and departmental and school resources before being able to charge pay continuation costs to sponsored awards.  This new requirement to exhaust other resources, and the documentation required, presents significant risk to the research enterprise.  For this reason, the University, like many of our peers, will no longer afford itself of this pay continuity flexibility.

If you have questions regarding Human Resources issues such as leave management, please contact the Human Resources representative for your department or school.  For grants management questions, please contact effort-reporting AT columbia.edu. A brief set of FAQs follows below.

 

Thank you for your attention to this matter.

Anne Sullivan
Executive Vice President for Finance and Information Technology

 

FAQs:

I have reorganized my team so that some people acquire data in the lab, and provide it to another team member who works completely remotely.  Do I need to make any changes to the salary allocations?

The usual effort and salary principles apply.  You should make sure that the individuals’ salaries are charged to the projects on which they are working, in accordance with their effort. If they are, then no changes are needed.

 

One of my team members has told me that, because of child care obligations, he is not able to work the equivalent of a full week, even though he is working at night and other times when possible.  What should I do regarding his salary?

You should ask him to estimate, on average, the percent of a regular week that he is able to work.  For example, if his estimate is that he is able to complete 80% of his regular week, then at least 20% of his salary should be charged to an unrestricted school account. 

 

One of my team members has told me that their hours are fluctuating month to month, but that overall, expects they will even out in the long run.  What should I do regarding their salary?

At this time, no changes may be warranted to this individual’s salary allocation, but you should monitor regularly and adjust if the hours do not even out as expected.