Faculty Guidelines for Allocation of Time and Salary to
Sponsored Projects
Introduction
Allocation of a faculty member’s time and salary is often complex and
depends upon the various activities in which the faculty member is
engaged. Faculty whose salary is supported on sponsored projects must
follow the requirements set forth by the federal government in the Office of
Management and Budget Circular A-21 and Dartmouth’s implementation of those
requirements. This document provides guidance for faculty and
administrators in complying with the requirements outlined by Dartmouth and
Circular A-21.
General Principles
Faculty may have several professional assignments in fulfilling their
responsibilities to the College. Teaching, research, clinical activities,
professional development and institutional service are common activities for
Dartmouth faculty. In general, the source of funding of salary for these
activities should be consistent with the effort in each area. In addition, all
of the effort that an individual provides in his/her capacity as a faculty
member must be part of the time that the College supports. There can be
no part of a faculty member’s job responsibilities that is not funded, i.e., no
volunteer responsibilities that relate to current or future Dartmouth
responsibilities. When a portion of a faculty member’s salary is funded
through federally sponsored projects, it is essential that there be another
source of salary support for activities that are not allowable or allocable
directly to sponsored projects under OMB Circular A-21.
Dartmouth Practices
When faculty have significant teaching, patient care or institutional
assignments while they are working on sponsored projects, Dartmouth expects
that there will be multiple sources of salary support that reflect effort in
those activities. Generally institutional funds are used to support
teaching, professional development and institutional service. To the
extent possible, sponsored funding should support faculty work on research and
demonstration projects although there are instances when institutional funds
support research.
In some cases, faculty effort and salary support can be attributed
predominately to sponsored projects. Even in those circumstances, most
faculty should not derive more than 95% of salary support from sponsored
sources during the course of a year. There may be special circumstances
where an individual has been released from teaching and clinical commitments
and has been relieved of all institutional assignments to spend 100% time on
his/her federally sponsored projects. In these cases it may be
appropriate to derive 100% support from sponsored sources.
In order to be certain that the College adheres to OMB Circular A-21
Guidelines, Dartmouth will take additional steps to monitor faculty effort and
sources of support for salary when an individual derives more than 80% of
salary from sponsored activities during any one academic quarter. For
these individuals, additional review will be conducted by the Office of
Sponsored Projects, which will consult with the relevant Deans to review effort
and salary support. Particular attention will be applied to assure that
significant institutional responsibilities including committee assignments,
student mentoring outside of the laboratory or research site (beyond “student
augmentation”) and administrative responsibilities are not funded by federally
sponsored activities. In addition, time spent preparing new grant
applications, including data gathering in research areas unrelated to existing
sponsored projects, cannot be supported by existing federally grants or
contracts unless they specifically allow such charges. The Dartmouth
Office of Sponsored Projects will be vigilant about interpretations of A-21
that clarify allowable and unallowable activities to be supported through
federally sponsored projects.
Documentation and Reporting
The Office of Sponsored Projects at Dartmouth will develop an augmented
documentation process to assure that there is affirmative record keeping for
faculty whose salary is derived more than 80% from sponsored projects to assure
that federal funds are being allocated appropriately for salary support.
Salary Cap and Cost Sharing
Some sponsors, most notably NIH and other HHS agencies, impose a cap on the
maximum rate or dollars that can be used in allocating salaries. Faculty
should work with their administrators and the Office of Sponsored Projects to
ensure compliance with sponsor imposed salary caps. Salary caps do not
reduce the time commitment expected by the sponsor. The time commitment
to the sponsor is based on the percentage of total effort the PI has stated
that he/she will devote to the project in the approved proposal, not the
percentage of salary charged to the grant.
Faculty may propose a level of time commitment, but not ask for salary
support at the same level or not at all. Faculty should consult the
policies of their respective schools and departments before doing so, and must
be able to support the proposed effort from a non-grant source. If the
proposal is funded, Dartmouth will be expected to document the salary that has
been cost shared equal to the time commitment. The department
administrator will work with the Office of Sponsored Projects to set the
accounts to track the cost sharing. All salary cost sharing must be
approved by the financial officer of the respective school. Individual
schools and departments may have other requirements.
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