Direct Costs: Salaries and Wages
Most commonly budgeted compensation costs include salaries, wages and benefits of Principal Investigators (PIs), Postdoctoral Researchers, Graduate Student Researchers (GSRs), Research Associates, Technicians, and other employees that directly further the goals of the project. All salaries and wages must be based on records that accurately reflect work performed, be reasonable for work performed, comply with the established UCI policies and procedures, and be consistently applied to both government and non-government activities.
Where grant recipients work on multiple grant programs or cost activities, documentation must support a reasonable allocation or distribution of costs among specific activities or cost objectives.
Additional Resources
- Uniform Guidance, §200.430 Compensation—Personal Services
- Contract and Grant Manual, Chapter 7-300, Justification and Documentation of Expenditures
PI and Other Key Personnel
The approved budget specifies the salaries of the PI and other key personnel, and their measurable effort dedicated to the project.
The PI must ensure that the sufficient levels of effort are committed to the project, and is required to request prior approval for the following changes in effort:
- Changes in a key person specified in the application or the Federal award.
- Withdrawal from the project or absence for any continuous period of three months or more.
- Reduction of the level of effort devoted to the project by 25 percent or more from what was approved by the sponsor.
Awards issued by DHHS agencies must adhere to the DHHS Salary Rate Cap limitations. The salary rate cap only affects employees whose rate is above the DHHS salary rate cap (currently $221,900 annually).
In accordance with NSF’s Grant Proposal Guide, NSF normally limits salary compensation for senior project personnel on awards made by the Foundation, to no more than two months of their regular salary in any one year. This limit includes salary received from all NSF funded grants.
Under normal rebudgeting authority, an internal increase in person months devoted to the project by senior personnel can exceed two-month salary policy restriction without a prior approval from NSF, 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.
Additional Resources
- UCI Office of Academic Personnel
- Academic Personnel and Programs
- UCI Office of Research - DHHS Salary Rate Cap
Graduate Student Researchers (GSRs)
GSRs working on a grant are generally paid salaries or wages, and benefits. The UCI Graduate Division’s Student Employment page and Graduate Policies and Procedures describe the regulations and processes related to the employment of graduate students.
Additional Resource
Clerical and Administrative Work
Salaries, wages, and fringe benefits for clerical and administrative work are normally treated as F&A costs. According to the Uniform Guidance, §200.413 Direct Costs, these expenses can be directly charged to the project only if all of the following conditions are met:
- Administrative or clerical services are integral to a project or activity;
- Individuals involved can be specifically identified with the project or activity;
- Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
- The costs are not also recovered as indirect costs.
In accordance with NSF’s Grant Proposal Guide, Chapter II.C.2g, proper justification for direct charging these expenses must be described in the budget justification for NSF awards. Direct charging of salaries and wages of administrative and clerical staff to NSF awards are only allowable if this type of cost is consistently treated as a direct cost in like circumstances for all other projects and cost objectives.
The NIH Grants Policy Statement, 8.1.1, states that NIH awards do not require prior approval to rebudget funds for this direct cost item post-award. Prior approval is only required when funds are being requested for such a position.
UCI requires that all salaries and wages of administrative and clerical staff charged to federal projects are supported by a proper justification for audit purposes, even if the federal sponsor waives its right to pre-approve these expenses.