Grants & Contracts News

Fiscal Year End

Fiscal Year End is quickly approaching and G&C is preparing for the close of another year.  Within the next few weeks, G&C will notify departments of state funded projects with an end date of 06/30/24.  The notification will include upcoming deadlines and tips to financially prepare for the end of FY24.

Please make sure PFFs, effective 07/01/24, are submitted in a timely manner and include the correct funding source(s).  The final payroll for sponsored programs ending 06/30/24 will post 07/15/24 and revised PFFs may be needed for the new Fiscal Year.

Publication Costs on Federal Awards

2 CFR 200.461 states that “publication costs,” including “costs for electronic and print media, including distribution, promotion, and general handling” are allowable as a direct cost when identifiable with a particular award.

Page charges for professional journal publications are also allowable when:

• The publication reports on the work supported by the award, and
• The publisher charges the same costs for all items published.

These costs may be incurred after the end date of the award but before award closeout. This means that the costs must be posted to the award at least 30 days in advance of the final financial report due date for the costs to be included in final invoicing/reporting. If it is anticipated that publication costs will need to be paid after closeout, then a No-Cost Extension (NCE) must be obtained or requested from the federal sponsor.

NSF 2-month Limitation on Salary

What is the NSF 2-Month Limitation on Salary?

As a general policy, NSF limits the amount of compensation in a proposal budget for Senior Personnel to two months per year from any combination of NSF funds.

Does the NSF 2-Month Limitation on Salary apply to the proposed budget or award expenditures, or both?

The NSF 2-Month Limitation on Salary applies only to the proposed budget. By this policy, NSF intends to limit the amount of funds institutions request from NSF, and therefore the amount NSF will award. However, NSF allows institutions to rebudget award funds within the terms of the award to pay individuals in excess of the 2-month limitation.

Can NSF make exceptions to the 2-Month Limitation on Salary?

Yes. Unlike the NIH Salary Cap, which is imposed as part of NIH’s annual appropriation, NSF can approve exceptions to its 2-month limitation. Investigators should include the additional salary for Senior Personnel within the proposal budget and sufficiently justify the need within the budget justification.

To Whom does the NSF 2-Month Limitation on Salary apply?

All Senior Personnel are included in this NSF limitation. However, as stated above the restriction is not absolute – with sufficient budget justification, investigators can propose more than two months per year of salary for senior personnel.

How long has the NSF 2-Month Limitation on Salary existed?

This limitation has existed for several decades, however, it has changed somewhat in recent years:

NSF originally imposed the limitation on 9-month faculty (faculty who only received institutional pay for nine months of the year and had to generate the other three months from sponsored research funding). NSF’s wording stated that it would not pay more than “2 summer months”.

In January 2011, NSF modified its wording from “2 summer months” to “2 months”. NSF’s intent was to clarify its policy to auditors and make things simpler for most awardee institutions.

In Fall 2014, NSF clarified that the limitation applied to proposal budgets, not to award expenditures, and that institutions could rebudget NSF funds to pay senior personnel in excess of two months per year, as otherwise allowed within the award terms.

NSF’s current statement regarding this requirement can be found under the Senior Personnel Salaries & Wages Policy section, Proposal Preparation Instructions of the NSF Proposal and Award Policy Guide; the 2016 version of the Guide can be found here: https://www.nsf.gov/pubs/policydocs/pappguide/nsf16001/gpg_2.jsp#IIC2gia

The NSF clarification of this policy is located under Senior Personnel under its Proposal FAQ 13-1, which can be found here: https://www.nsf.gov/bfa/dias/policy/papp/papp13_1/faqs13_1.pdf