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Policy No.: 6102
Effective Date: 02/20/06
Revised Date: 03/09/23
Reviewed Date: 03/09/23

Institutional Base Salary Policy

Purpose

The purpose of this policy is to define compensation and Institutional Base Salary (IBS) for the purposes of:

• generating budgets for sponsored project proposals.
• charging compensation for personal services to sponsored projects.
• documenting compliance with National Institutes of Health (NIH) regulations and criteria for combining practice plan and university salaries as the basis for University of Nebraska Medical Center (UNMC) IBS.

It applies to all individuals:

• whose salary, in whole or in part, is budgeted on or charged to a sponsored project.
• who have committed effort to a sponsored project, whether that effort is charged to the sponsored project or cost-shared (see UNMC Policy 6104, Sponsored Project Cost Share), by UNMC.

Failure to properly budget, document IBS or charge awards, may result in expenditure disallowances, financial penalties, disciplinary actions, audit findings and harm to UNMC’s reputation.

Policy

The University of Nebraska Medical Center (UNMC) Institutional Base Salary (IBS) represents combined salary from UNMC and its affiliate practices' plans, Nebraska Medicine and Nebraska Pediatric Practice. Veterans Administration salary is not included in the IBS, per NIH Grants Policy Statement.

Definitions

Per Uniform Guidance Section 200.430 Compensation - Personal Services

• Institutional base salary is defined as the annual compensation paid by an institution of higher education for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities. IBS excludes any income that an individual earns outside of duties performed for the institution of higher education. Unless there is prior approval by the Federal 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.

In conformance with Uniform Guidance Section 200.430, UNMC salaries can be charged to sponsored awards if the salary:

• is reasonable for the services rendered and consistently applied to both Federal and non-Federal activities.

• compensation for employees engaged in work on Federal awards will be considered reasonable to the extent that it is consistent with that paid for similar work in other activities at UNMC, or comparable to that paid for similar work in the labor market in which UNMC competes for the kind of employees required for Federal awards but are not currently employed at UNMC.

• follows a faculty appointment made in accordance with UNMC policy and procedures.
• is properly allocated to the project and certified in accordance with UNMC Policy 6105, Effort Certification. The Effort Certification process ensures that UNMC maintains records that accurately reflect the work performed and that are supported by internal controls which provide reasonable assurance that the compensation charges are allowable, reasonable, consistently applied, and properly allocated.
• complies with the established accounting policies and practices of UNMC and is incorporated into the official records of UNMC.
• reasonably reflects the total activity for which the employee is compensated, not exceeding 100% of compensated activities.

Components of Institutional Base Salary

UNMC Institutional Base Salary (IBS) is the annual compensation for an employee’s appointment, whether for research, teaching, public service, administration or other activities. IBS wage codes are defined in UNMC’s Wage Code Types. IBS excludes some wage code types; therefore, IBS may be less than the total institutional salary.

UNMC IBS includes four major parts:

• UNMC base salary
• Specified UNMC stipends
• Nebraska Medicine Practice base salary
• Nebraska Pediatric Practice base salary

UNMC IBS excludes:

• Supplemental compensation
• One-time payments
• Veterans Affairs (VA) salary (paid directly by VA to the employee)
• Nebraska Medicine Practice bonus payments
• Nebraska Pediatric Practice bonus payments

Other Factors that May Impact IBS

• UNMC allows an annual inflation factor comparable with the most recent University of Nebraska budget increase to be applied to sponsored project budgets. Note: Although NIH allows applicants to request cost-of-living increases in accordance with institutional policy, NIH eliminates such increases from awarded budgets.
• UNMC IBS may not be increased as a result of replacing UNMC funds with sponsored project funds. Salary Increases of 10% or more during the fiscal year must be approved by following the process explained in UNMC Policy 1007, Compensation Administration.
• For NIH and other Health and Human Service agency grants, the Consolidated and Further Continuing Appropriations Act, 2015 (Public Law 113-235) limits the IBS to Executive Level II of the Federal Executive pay scale, currently set at $212,100.
• For federal contracts, 41 U.S.C. 4304(a)(16) limits the reimbursement of compensation costs for contractor employees to $619,000, adjusted annually.

UNMC Compliance with NIH Criteria for Combining Salaries

The University of Nebraska Medical Center (UNMC) Institutional Base Salary represents combined salary from UNMC and its affiliates’ practice plans that include both Nebraska Medicine, and Nebraska Pediatric Practice.

In addition to Uniform Guidance requirements explained above, to be eligible to incorporate the clinical practice plan salary into the IBS, NIH applicant institutions must meet five criteria outlined in the NIH Grants Policy Statement. UNMC meets each of the following five criteria.

1. Clinical practice compensation must be set by the institution.

• Per UNMC policy and practice, clinical practice compensation is set by department chairs who report to the Dean of the College of Medicine.

2. Clinical practice activity must be shown on the institution's payroll or salary appointment forms and records approved by the institution.

• Per UNMC policy and procedure, faculty assignments and compensation are documented on annual terms of employment agreements issued by the College of Medicine Dean’s Office and in annual Nebraska Medicine and Nebraska Pediatric Practice Employment Agreements. Nebraska Medicine and Nebraska Pediatric Practice are instrumentalities of the University of Nebraska and acts as common paymaster for their clinical practice faculty.

3. Clinical practice compensation must be paid through or at the direction of the institution.

• Per UNMC policy and procedure, faculty assignments and compensation are documented on annual terms of employment agreements issued by the College of Medicine Dean’s Office and in annual Nebraska Medicine and Nebraska Pediatric Practice Employment Agreements. Nebraska Medicine and Nebraska Pediatric Practice are instrumentalities of the University of Nebraska and acts as common paymaster for their clinical practice faculty.

4. Clinical practice activity must be included and accounted for in the institution's effort reporting and/or payroll distribution system.

• Per UNMC policy and procedure, UNMC includes clinical practice activity in its effort certification system and payroll distribution system.

5. The institution must assure that all financial reports and supporting documents associated with the combined IBS and resulting charges to NIH grants are retained and made available to Federal officials or their duly authorized representatives consistent with the requirements of Uniform Guidance § 200.333.

• Per University of Nebraska policy (see Sponsored Project 170-8}, UNMC assures that all financial reports and supporting documents associated with the combined IBS and resulting charges to NIH grants are retained and made available as required by federal regulations.

Roles and Responsibilities

Deans, Directors, and Chairs

• Provide appointment letters to faculty
• Review and approve faculty workload
• Review effort commitments and IBS on ADIS Internal Forms budgets for new awards

Faculty

• Commit effort to each sponsored project for which he or she is serving as Principal Investigator or as other key personnel
• Certify 100% of one’s UNMC effort on Effort Certification Reports, as required by UNMC Policy 6105, Effort Certification

Department Administrator

• Prepare sponsored project budgets, both in proposals to be submitted to sponsors for consideration and in ADIS Internal Forms
• Enter payroll distribution in SAP based on approved budget and adjust payroll based on actual certified effort, as required by UNMC Policy 6105, Effort Certification

Sponsored Programs Administration

• Review and approve sponsored project budgets, both in proposals submitted to sponsors for consideration and in ADIS Internal Forms
• Use RSS to verify IBS used in sponsored project budgets

Sponsored Programs Accounting

• Ensure that effort certifications are completed in compliance with UNMC Policy 6105, Effort Certification and review cost-shared (UNMC Policy 6104, Sponsored Project Cost Share) companion accounts for accuracy
• Ensure that IBS Wage Code Types in SAP are properly updated and compliant with this policy, (UNMC Policy 6102, Institutional Base Salary).

Additional Information

• Senior Manager, Financial Compliance and Cost Analysis
• Financial Compliance and Cost Analysis
• UNMC Policy 1007, Compensation Administration
• UNMC Policy 6104, Sponsored Project Cost Share
• UNMC Policy 6105, Effort Certification
• Wage Code Types Applicable for Sponsored Projects
  
• UNMC Standardized Budget Justification Language
  

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