NSF 2-month salary rule
continues to garner OIG scrutiny
In several audits of institutions of higher education this year the National Science Foundation’s (NSF) Office of the Inspector General (OIG) has continued to question costs that exceed NSF’s two-months-per-year limit on salary charged for senior personnel to NSF awards. Recently, Columbia University joined over two dozen institutions with OIG findings that collectively questioned millions of dollars of salary expenditures. At the same time, NSF is standing behind its policy that more than two-month’s salary can be allowable in certain situations. (NSF PAPPG 16-1, Chapter II.C.2.g(i)(a)) As this tug-of-war between NSF and it’s OIG continues, the Research Office reminds the UD research community that strong justifications explaining the need for senior personnel salary are critical for proposal budgets and budget modifications that will result in senior personnel receiving more than two-month’s salary in a year (overall NSF funding for the individual). If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award. To provide further internal controls, the Research Office has instituted internal system reviews to identify costs that exceed the two-month limit and will contact departments and colleges if/when a cost is identified on this report.