Guidance for Charging Salaries to Sponsored Research Budgets

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5 years 2 months
Submitted by mdavis25 on

If Work Directly Related to an Award Cannot be Conducted Due to COVID-19 Disruptions

Federal Sponsors have provided additional flexibility regarding how effort is expended on awards that have been disrupted due to COVID-19. The following guidelines have been developed for departments to follow in the event of a disruption.

First, every effort should be made to identify activities that can be performed remotely or in accordance with public health guidelines AND relate to the award objectives or further the skills of the researchers on an Award. This includes activities that are not expected to directly contribute to progress on the award, such as reviewing materials, analyzing data, learning a related software program or other skill, or organizing and cleaning materials or data sets.

In the event that no such activities can be identified, the department should consider reassigning researchers or staff to other funded activities. For example, there may be other sponsored awards that could take advantage of the effort additional researchers could provide. This would be allowable as long as the award has sufficient funds and, if necessary, the ability to re-budget to accommodate the additional effort. There may also be departmental or other unrestricted funding sources that could be utilized.

In the exceptional case that alternative work arrangements or reassignment cannot be identified, both federal and non-federal sponsors may allow charging of salaries to an award, even when the researcher is unable to work on that award.  You can review the sponsor’s specific policies on COVID-19 (COGR has a webpage on sponsors’ COVID-19 policies) to determine if the sponsor allows for such flexibility and what the individual sponsor requirements are for complying with their policy.

If the sponsor has not provided broad flexibility or has not issued guidance on this topic, please work with OSP to seek sponsor approval prior to charging.

When exercising additional flexibility, please remember the following:

  • There should be communication with the sponsor on the activities identified for the researchers. Again, federal sponsors are being flexible about effort, but communication with the sponsor is important to ensure they are aware of the steps being taken to mitigate the effects of the disruption.
  • The amount of salary to charge cannot exceed the level charged prior to the COVID-19 impact, and in any case, no more than the amount of salary commensurate with the effort level committed in the proposal or last progress report.
  • Sponsors have indicated that charging salaries while unable to work may negatively impact the award by creating a project budget shortfall. There is no guarantee sponsors will supplement with additional funding. 
  • If you have to quarantine, take care of a family member that must quarantine, or take care of a minor child, additional support is available. Please work with your HR Consultant  about other forms of available leave.

Mary Lidstrom and Sue Camber