Guidance on Applying the National Science Foundation (NSF) Salary Policy

Does the NSF salary rule apply to all faculty members and staff charged to an NSF grant?

No. The NSF policy applies only to senior project personnel. The NSF Grants Policy Guide (GPG) defines senior personnel as:

• (Co) Principal Investigator(s) - the individual(s) designated by the proposer, and approved by NSF, who will be responsible for the scientific or technical direction of the project.
• Faculty Associate (faculty member) - an individual other than the Principal Investigator(s) considered by the University to be a member of its faculty or who holds an appointment as a faculty member at another institution, and who will participate in the project being supported.

Who does the NSF two-month salary policy NOT apply to?

The NSF two-month' salary policy does not apply to:

• Other personnel not budgeted as senior personnel
• "Soft-funded" employees (faculty positions that are not supported by permanent operating budget dollars)

Can NSF salary support be requested for summer and academic year effort?

As a general rule under the revised policy, salary for senior project personnel is limited to two months of extra compensation during the summer for individuals on 9-month contracts.

Alternatively, 9-month or 12-month employees may use NSF funds to support a buyout of time during the academic year or during the summer (only for 12-month employees). All salary charges must be supported by the actual effort expended. If it is determined that it is more suitable to propose and charge academic year salary, it is up to the senior project personnel and his/her department head/dean to determine how best to manage academic year salary savings.

Why can't a 9-month faculty or a 12-month faculty member receive extra compensation through an NSF grant during the academic year or during the summer for 12-month faculty members?

It is assumed that grant work falls under the scope of a faculty member's regular duties as outlined in their appointment letter, which typically includes teaching, mentoring, research, and service. If a faculty member's grant activities are above and beyond the duties outlined in their appointment letter, a faculty may request to use NSF funds to provide a course release or buyout time spent on other activities related to their appointment, freeing up their time to work on grant activities.

Is funding in excess of 2 months' salary allowable?

Yes, provided NSF approves it in advance. The two months is not a hard cap or ceiling. Fisher should propose salary for senior project Personnel in a manner that is suitable to the project. As the revised policy states: "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 notice."

Does greater than two months' salary for senior personnel budgeted on multiple NSF awards constitute as approval from NSF to charge greater than two months' salary on NSF funds?

"Yes, per informal NSF guidance, as long as the person months are listed in the approved budget that is attached to the NSF award notice, it constitutes NSF approval.  It is also important to disclose all effort spent on all NSF and non-NSF research/grants in the current and pending document attached to the proposal."

How is the one-year period determined?

The revised policy identifies the salary limit as applicable to "any one year." Fisher defines the one year period as the academic year beginning with the fall semester and ending with the summer semester.

If senior project personnel plan to spend additional time working on the project, if it is funded, how should this be reflected in the proposal?

The budget should only show the salary being requested and the corresponding person months related to that salary for the senior personnel.

While the Current and Pending Support section of the NSF proposal may show the total person months projected to be spent working on the project by the senior personnel, the Facilities, Equipment and Other Resources section is what should be used to provide a narrative description of the resources available (both physical and personnel) to the project.

If a PI is being paid 100% from only NSF award(s) or NSF flow-through award(s) must they devote 100% effort to these awards and to no other activities?

Yes.