Research Administration Guidelines
RAG64 Salary Caps
Subject Matter Expert:
Policy Steward:Senior Vice President for Research and Associate Vice President for Budget and Finance>
Policy RA64 - Personnel Costs provides detail on appropriate management of personnel costs to comply with the Uniform Guidance, specifically Uniform Guidance 2 CFR 200.430 Compensation – personal services. This guideline provides more detail on salary cap documentation requirements.
Certain federal agencies have established reimbursement salary caps. If an individual whose salary exceeds the cap is performing effort on an account subject to a reimbursement salary cap, the amount charged to the account for each month must be calculated to account for the cap.
Any difference between the actual percent of effort and the percent of effort charged must be tracked and charged to the same budget function (function code) as the agreement (Instruction, Research, or Outreach). Amounts over the salary caps are NOT allowable costs, and therefore are not permitted as cost sharing.
To illustrate the application of these guidelines, the following example has been prepared:
Assume that Dr. Sal Kapp earns $162,000 per academic year on an academic 36 week appointment. They have committed 25% of their effort to a sponsored project, but the sponsor limits the salary to no more than $191,300 per year. Dr. Kapp's annualized monthly salary is equivalent to $18,000 or $162,000 / 9 months. The imposed salary cap monthly salary is equivalent to $15,941.67 or $191,300 / 12 months. An adjustment will need to be made on the amount being paid on the sponsored project taking into consideration Dr. Kapp's 25% percent of effort and the maximum allowable amount. The monthly salary costs for the project effort would be $4,500 or $18,000 * 25%, but the maximum allowable monthly salary cost would be $3,985.42 or $15,941.67 *25%. Therefore, the percent of effort that can be charged to the sponsored project would be 22.14% or $3,985.42 / $4,500 * 25%. The amount of salary not reimbursed by the sponsored project would be $514.58 per month or $4,500 - $3,985.42.
All individuals whose salary is impacted by a salary limitation shall indicate concurrence at the time of award with the following language:
"I understand that the sponsored project titled "insert title" sponsored by "insert sponsor" has imposed a cap on my salary reimbursement. In the event that allowable non-federal funds are unavailable or only partially available to support the portion of my salary above the imposed cap, I understand that my rate of pay will be below my annualized monthly salary. It will be my responsibility to identify the source of allowable non-federal funds, subject to Budget Administrator/Budget Executive approval."
If Dr. Kapp receives their full salary, the $514.58 balance of their monthly salary must be charged to an account with the same function code as the sponsored project.
Please note that the NIH salary cap is updated annually effective January 1st and should be taken into consideration for effort certification notations. Current NIH Rate caps listing. Other agencies may also have salary caps, which could be different than those referenced for NIH, so verify the caps based on agency guidelines and regulations. There is no centralized source summarizing all salary caps in effect.
The amount of salary over the cap must be accounted for within Labor Distribution and should be charged to a non grant cost collector to assure that it is appropriately included in the cost base for F&A purposes. Units should set up a unique cost center to track the amount over a salary cap so these amounts can be easily identified.
The amounts over the salary cap CANNOT be used as cost sharing. See Cost Sharing FAQ for additional detail.
For questions, additional detail, or to request changes to this policy, please contact the Office of the Senior Vice President for Research or the Office of Budget and Finance.
Other Policies should also be referenced, especially the following:
RA21 - Development of Proposal Budget
RA64 - Personnel Costs
June 1, 2021 - Updated to reflect SIMBA procedures.
September 18, 2019 - Changed Vice President for Research to Senior Vice President for Research
- February 26, 2016 - This new guideline (incorporating parts of RA08) has been created as part of the policy reorganization brought about by implementation of the Uniform Guidance (2 CFR 200).
Date Approved:February 22, 2016>
Date Published:May 31, 2021>