POLICY PURPOSE:

This policy establishes Colorado State University Pueblo’s definition of Institutional Base Salary (IBS) and the basis for calculating faculty salaries and those of other employees with exempt classifications. The purpose is to describe the allowable activities in proposals and on awards in order to comply with federal regulations as described in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), 2 CFR 200.430, which require that federal awardees establish a consistently applied definition of IBS. Financial penalties, expenditure disallowances, and harm to CSU Pueblo’s reputation could result from the failure to accurately propose, charge, and/or document faculty salaries relating to sponsored projects, whether charged directly or provided as cost sharing. The purpose of this Policy is to provide requirements and guidelines for IBS for all sponsored programs at the University.

POLICY APPLIES TO (Persons affected by):

This policy applies to all faculty members and other exempt employees whose salary is charged to sponsored projects, in whole or in part, and who have committed effort to a sponsored project but receive no salary support from the sponsored project (i.e., their salary is paid from CSU Pueblo funds and constitutes voluntary or mandatory committed cost sharing).

DEFINITIONS:

Institutional Base Salary (IBS): As defined in 2 CFR 200.430(h)(2), IBS is the annual compensation paid by CSU Pueblo for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities.

• For nine-month appointments, IBS is for the 9-month period. For 12-month appointments, IBS is for annual compensation.
• The compensation relevant in determining IBS is the amount that is guaranteed and fixed in advance by the appointment letter and paid through the payroll system.
• IBS does not include salary paid directly by another organization or income that an individual is permitted to earn outside of their university responsibilities, for example, from consulting. IBS also does not include amounts paid as honoraria, nor items such as a housing allowance, tuition reimbursement, or non-compensatory benefits. IBS does not include one-time payments for a one-time event or activity paid through supplemental pay.

POLICY STATEMENT:

The federal government requires recipients of federal funding to establish an institutional policy that documents the budgeting and expensing of salaries on sponsored projects, whether charged directly or provided as cost sharing, and treats them consistently across all funding sources. CSU Pueblo will maintain compliance with federal guidelines by using IBS for purposes of salary requests and/or effort commitments on all sponsored projects. This document sets forth the University’s definition of Institutional Base Salary (IBS) for sponsored projects and for effort reporting purposes.

IBS must be used as the base salary on all grant proposals unless there is a prescribed limit on compensation (e.g., awarding agency salary cap).

Unless there is prior approval by the awarding agency, charges of a faculty member's salary to a federal award must not exceed the proportionate share of the IBS for the period during which the faculty member worked on the award.

If a sponsored project has a salary rate cap, then an individual's salary in excess of the salary rate cap is considered an unallowable cost. The unallowable portion of salary over the cap may not be charged to a regular cost sharing cost center of the project. It must be charged to a non-sponsored, nonfederal fund cost center.

Department heads will provide appointment and salary change letters to faculty and other employees paid on sponsored projects, indicating the approved institutional base salary and approximate effort distribution.

A faculty member's IBS is established in the member’s offer letter and updated by any notice of an annual raise. Data for each appointment will be entered into the payroll system by department personnel when the appointment letter is approved. Departments will retain copies of appointment and salary letters for audit purposes.

IBS may not be increased solely because of the University having received an externally sponsored award.

Summer Salary: Faculty members on nine-month appointments may be compensated for work on sponsored projects during the summer, with the salary based on the IBS of the previous academic year and the level of summer effort devoted to the project.

IBS should be reviewed annually by the employee and the department chair/director and may be changed at the beginning of any fiscal year. Subject to all required approvals, any change to the IBS will be reported by the department head/director to Human Resources, who will update the IBS in the HR system. During a fiscal year, IBS of an employee generally will not change. However, it may be changed in the following limited circumstances:

The employee’s formal appointment, and required professional effort, is changed from full-time to part-time, or vice-versa, or from one required level of part-time effort to another required level of part-time effort;

The employee receives an increase or decrease in salary as a result of assuming or relinquishing specific academic or administrative duties, e.g., serving as a department head or director, promotion or other change in employment responsibilities; or

The employee receives a salary increase as a result of an adjustment due to promotion in rank or position or as part of a University-wide adjustment of salaries.

The Office of Research and Sponsored Programs (ORSP) will review sponsored project direct expenditures and cost sharing for accuracy. The terms and conditions of the solicitation should be reviewed for salary rate caps before submitting a proposal. When such limitations apply, the requested salary support is determined by multiplying the proposed level of effort by the maximum IBS allowed.

Failure to comply with this Policy can result in financial penalties, expenditure disallowances and harm to the University’s reputation. Failure to accurately propose, charge and document salaries related to sponsored projects could also jeopardize future sponsored projects and may subject the responsible individuals to disciplinary action. Therefore, compliance is mandatory. For compliance assistance, contact the ORSP.

RELATED LAWS, POLICIES & PROCEDURES:

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200

CSU Pueblo Office of Research and Sponsored Programs, Principal Investigators Manual

FORMS:

Effort Reporting Form

APPROVAL:

Approved by Timothy Mottet, President, 12/5/2023