Division of Research
Identifying Costs Exceeding the NIH Salary Cap
What Is the Salary Cap?
The salary cap, or salary limitation rate, applies to any individual whose salary is charged directly to awards from these agencies. The rates are set by the U.S. Congress as part of the annual federal budget appropriations process. The Federal Executive Pay scale changes January 1 each calendar year. Effective January 1, 2024, the salary limitation for Executive Level II is $221,900.
The salary cap limits the rate of academic and summer salary that may be charged to NIH, SAMHSA, and AHRQ awards. Brown University considers academic or calendar year salary in excess of the imposed cap as mandatory cost sharing. The amount in excess of the cap cannot be used as matching funds. The University may pay an employee’s salary amount in excess of the salary cap from non-sponsored project funds.
NIH will fund the salary cap at the level in effect at the time the competitive award is issued. If, during the period of that award, the salary cap is increased, under applicable rebudgeting authority the salary may be paid at the higher level. NIH, however, will not award any additional funds for this purpose.
Brown University Statement on NIH Salary Cap
Brown will comply with all salary cap requirements of sponsors making awards to the University in support of research or other activities. Where an agency specifies a maximum rate at which an individual may be paid from that agency’s funds, Brown will ensure that any salary above that rate will not be charged against the grant, contract or cooperative agreement issued by that agency. Salary in excess of the salary cap is considered mandatory cost sharing and should be identified during the proposal phase of an award.
Proposal Stage
It is Brown’s policy that documentation related to all awards from NIH, SAMHSA and AHRQ with individuals whose salary is above the salary cap include the Salary Cap Worksheet. Additional guidance is provided below.
Award Stage
Once an award has been made, the costing allocation is submitted through Workday and the salary reflected on the costing allocation must conform to the applicable salary cap in effect.
When preparing the costing allocation, the monthly salary amount charged to an NIH award during the academic year and/or summer cannot exceed the NIH monthly cap rate multiplied by the percentage of effort.
The completed Salary Cap Worksheet must be attached to the costing allocation in Workday.
Effort Certification Report
When completing effort reports, the reported percentage of effort for an individual over the salary cap must represent a reasonable estimate of effort expended on the project, not the percentage of salary charged. This percentage must include the effort that could not be charged to the award because of the salary cap. View the NIH Salary Cap Policy for details.
Institutional Base Salary
Institutional Base Salary is the total guaranteed annual compensation an individual receives from Brown University. This number is used to compute salaries charged to NIH-sponsored programs. The Institutional Base Salary should include an individual’s academic year salary as well as any stipend received from performing other administrative duties, whether as a center director, department chair or program director.
Salary Cap Roles and Responsibilities
- Principal investigators (PIs)
- are responsible for managing project funds in compliance with sponsor requirements; ensuring appropriateness and accuracy of effort expended on a sponsored project; and ensuring compliance with any salary limitations imposed by sponsors.
- Department administrators
- are responsible for establishing effective policies and controls to ensure compliance with this policy; identifying all individuals whose salary is over the cap; preparing proposals and applicable documents in accordance with policies and procedures; and ensuring compliance with any salary limitations imposed by sponsors.
- The Office of Sponsored Projects
- is responsible for maintaining communications with funding agencies to assure understanding of agency requirements; developing and implementing salary cap policies, procedures and training sessions in accordance with sponsor regulations; reviewing proposals, awards and other associated documents to ensure compliance with policies and procedures; and ensuring compliance with any salary limitations imposed by sponsors.
Reflecting the Salary Cap in Your Proposal Budget
Those who are preparing proposal budgets with an investigator salary in excess of the Salary Cap should complete the Salary Cap Worksheet using the instructions provided below and in the spreadsheet.
Use the tabs at the bottom of the Excel spreadsheet to navigate as needed between the proposal and award stages, which differ slightly to capture the necessary information required at each grant stage. The Proposal Stage worksheet is designed to capture the percentage charged for salary over the cap for each fiscal year of the project. It also includes a column to capture the appropriate percentage charged when effort changes within a fiscal year.
Download the Salary Cap Worksheet [XLS]
How to Complete the Proposal Stage Worksheet
Enter the individual’s name (labeled Faculty Name), current salary and escalation rate in the top portion of the spreadsheet.
The academic year (AY) salary will automatically calculate for each fiscal year available in the spreadsheet based on the information entered in the previous step.
The spreadsheet is divided into three sections based on appointment type: 12-Month Appointment; 10-Month Academic Appointment and Summer Salary; and 9-Month Academic Appointment and Summer Salary. Navigate to the appropriate section of the spreadsheet based on the appointment type of the individual and enter their percent (%) effort on the project for each Brown fiscal year of the project (Column B).
It is important to keep in mind that in most cases the project periods will not correspond to the Brown fiscal years (07/01/XXXX–06/30/XXXX). For example, if the project period is 09/01/2021–08/31/2024, that encompasses the following Brown fiscal years:
| Project Period | Brown Fiscal Years (FY) |
|---|---|
| 09/01/2021–08/31/2022 | FY2023 and FY2022 |
| 09/01/2022–08/31/2023 | FY2022 and FY2023 |
| 09/01/2023–08/31/2024 | FY2024 and FY2025 |
Save your worksheet and label it with the individual’s name. A separate worksheet must be completed for each individual whose salary is over the Salary Cap.
How to Enter Salary Cap Information into Coeus
The Salary Cap information you have entered into the Salary Cap Worksheet is added in the budget section of Brown’s grant management system, Coeus, by using line items under Personnel (or Personnel Cost) that describe who will be paid out of the award if the proposal is funded. Keep in mind that the Budget Persons window must be completed first before you can add personnel to the budget.
Enter information into the Budget Persons window as you normally would. For individuals whose salary is over the Salary Cap, enter their actual salary information in the Calculated Base (Calc. Base) field — not the Salary Cap amount.
Add the appropriate Personnel line item (Personnel Cost Element). Following are the Personnel line items available in Coeus for Salary Cap entry:
- Faculty Salary — NIH CAP — Academic Year
- Faculty Salary — NIH CAP — Summer
- Faculty Salary — NIH CAP — Non-Regular Research
Select the appropriate line item based on the individual’s appointment type and the period that they will be working.
Add the individual into the Personnel line item. Adjust the start and end dates in the Personnel Budget Details window to reflect the correct period. If the project period crosses Brown fiscal years, split the project period into the appropriate fiscal years. (This step is necessary because the salary for faculty and staff is set to increase every July 1.)
In the Percent (%) Charged field, enter the “% distribution to the NIH account” number calculated in the Salary Cap Worksheet for the appropriate fiscal year.
In the Percent (%) Effort field, enter the individual’s percent effort on the project.
After you “Generate All Periods” of the budget, you will need to go into each Salary Cap Personnel line item and manually adjust the Percent (%) Charged for each Brown fiscal year based on your Salary Cap Worksheet.
How to Distribute ‘Over the Salary Cap’ Cost Share
Because the Percent (%) Charged and Percent (%) Effort amounts in the Salary Cap Personnel line items are different, an amount will be generated in the Cost Share field. The Cost Share Amount represents the salary amount being shared as well as the associated fringe benefits and indirect costs. All Brown University’s cost-sharing on proposals needs to be recorded in the Budget section of Coeus and distributed accordingly to the appropriate accounts.
While in the Budget section, select Edit → Cost Sharing Distribution from the menu bar to open the Modify Proposal Cost Sharing window. The Total Cost Sharing field displays the full amount that needs to be distributed to accounts by project period (Brown fiscal year).
Enter cost sharing dollar amounts in the Amount field for each project period. You must enter an account that will be responsible for the Cost Share Amount in the Source Account field for each project period.
For those amounts that represent the “over the salary cap” Cost Share (plus associated fringe benefits and facilities and administrative costs), you must enter “NIHCAP” in the Source Account field for each project period. (An actual account number does not get assigned to this type of Cost Share.)
Click the OK button to close out of the Modify Proposal Cost Sharing window.
Answering Yes/No Questions in Coeus
Because your proposal includes salaries that are over the cap, you must answer “yes” to Brown University Question 0B18 in Coeus: “If applicable, are proposed salaries over the cap? If yes, include NIH Salary Cap Worksheet with submission.”
To answer this question:
- From the Proposal Details section, navigate to the Yes/No Question section by selecting Edit → Yes/No Questions from the menu bar; and
- In the Proposal Question window, scroll down to question 0B18 and answer “yes” to the question by selecting the “YES” radio button.
How to Upload the Salary Cap Worksheet to Coeus
Finally, the Salary Cap Worksheet that you have completed must be uploaded in the Narrative section of Coeus.
- From the Proposal Details section, navigate to the Narrative section in Coeus by selecting Edit → Narrative from the menu bar, then
- In the Narrative for Proposal window, select Edit → Add to open the Add Module window, then
- In the Add Module window, select the Narrative Type by clicking on the arrow to the right of the Narrative Type field. For the worksheet, select Salary Cap Worksheet Narrative Type, then
- To upload the worksheet to the Narrative module, click the [Upload] button in the Add Module window to navigate to your computer files and upload the desired attachment. Select the desired file on your computer or network and click the [Open] button. The document name will appear in the File Name field.
- Remember to upload a separate Salary Cap Worksheet for each individual whose salary is over the salary cap, then
- Set the status of your attachment to either Complete or Incomplete in the Status field. Click on the [OK] button to exit out of the Add Module window and return to the Narrative for Proposal section.
Restricting Access to Salary Information
Because the worksheet has salary information, you can limit the access to the attachments, if need be, to other individuals assigned to the proposal. This is done by setting restrictions on the Salary Cap Worksheet narrative type. You will assign Narrative attachment rights to the appropriate users listed at the bottom of the Add Module window for the document uploaded.
Assign one of the following rights to each user when attaching documents to the Narrative section in Coeus:
- Read: The user can view the attachment only
- Modify (default): The user can view and edit the attachment
- None: The user does not have the rights to view or edit the attachment
How to Include a Statement in Budget Justification
Because the proposal includes salaries that are over the cap, you must include an explanation in the Budget Justification section. This statement should follow a basic format, such as:
“Personnel [name] will devote [#] Percent of a 1.0 FTE appointment with Brown University toward the goals of this project. Their current Institutional Base Salary exceeds the NIH salary cap. Brown University’s institutional policy is to request and charge all NIH-sponsored projects at the NIH salary cap for those salaries that are in excess of the cap. Therefore, this application requests salary at the current NIH salary cap. The salary over the NIH salary cap will be accounted for in accordance with federal policy.”