dhhs salary cap (us department of health and human services). the following is provided as a brief...
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DHHS SALARY CAP(US DEPARTMENT OF HEALTH AND HUMAN SERVICES)
. THE FOLLOWING IS PROVIDED AS A BRIEF SUMMARY OF THE HHS SALARY CAP REQUIREMENTS.
UPDATED AUGUST 2015
EAST CAROLINA UNIVERSITYOFFICE OF GRANTS AND CONTRACTS
HHS SALARY CAP• DHHS IMPOSES A MAXIMUM SALARY CAP (ANNUAL SALARY RATE THAT CAN BE PAID)
FOR ALL OF THEIR AWARDS.
• THE SALARY CAP RATE CHANGES PERIODICALLY.
• THE RATE THAT IS IN EFFECT AS OF THE TIME OF AN AWARD, AND SALARY BEING CHARGED, IS THE RATE THAT MUST BE USED.
• PRIOR TO 12/11 THE SALARY CAP ONLY APPLIED TO NIH, AHRQ AND SAMHSA.
• THE SALARY CAP NOW APPLIES TO ALL HHS AGENCIES.– NIH, AHRQ, SAMHSA, CDC, HRSA, ACF, ACYF, AOA, ATS-DR, CMMS, FDA AND IHS
• SOME NON-PROFITS, SUCH AS AMERICAN HEART ASSOCIATION, HAVE ALSO ADOPTED THE HHS SALARY CAP RATE.
EFFECTIVE DATES• THE SALARY CAP IS BASED ON THE FEDERAL EXECUTIVE LEVEL II SALARY RATE.
• FOR AWARDS ISSUED 10/1/14 THROUGH 1/10/2015, THE SALARY CAP IS $181,500/YEAR (FOR 12 MONTH, 1.0 FTE).
• FOR AWARDS ISSUED 1/11/15 THROUGH SEPTEMBER 30, 2015, THE SALARY CAP IS $183,300/YEAR (FOR 12 MONTH, 1.0 FTE).
• THE RATE MAY CHANGE AGAIN, WHEN THE 15-16 FEDERAL BUDGET IS PASSED, OR IT MAY STAY THE SAME FOR A NUMBER OF YEARS.
• CHANGES TO THE SALARY CAP ARE USUALLY ANNOUNCED IN JANUARY/FEBRUARY BUT MAY BE RETROACTIVELY APPLIED.
• OGC WILL NOTIFY THE CAMPUS WHEN THERE IS A CAP RATE CHANGE.
SALARY RATES
• BECAUSE OF STAGGERED IMPLEMENTATION/AWARD DATES, AN INDIVIDUAL COULD HAVE MORE THAN ONE CAP IF PAID FROM MULTIPLE HHS AWARDS OR A COMBINATION OF HHS AND OTHER SPONSOR CAP AWARDS.
• THE SALARY CAP IS A RATE OF PAY – NOT JUST A CUMULATIVE AMOUNT PAID OR CHARGED TO AN AWARD.• $183,300/YEAR MAX• $15,275/MONTH MAX• $7,637/PAY PERIOD MAX
• EFFORT COMMITMENTS REMAIN THE SAME. IT IS ONLY THE RATE OF PAY THAT MAY CHANGE.
• THE CAP RESULTS IN MANDATORY COST SHARE FOR ANYONE WITH A UNIVERSITY SALARY HIGHER THAN THE CAP.
EPAFs AND COST SHARE
• OGC WILL NOT APPROVE EPAFS THAT EXCEED THE APPROPRIATE HHS CAP LIMITATIONS FOR HHS OR OTHER CAP AWARDS.
• ADMINISTRATORS SHOULD REVIEW FOR THE SALARY CAP RESTRICTIONS WITH EACH NEW AWARD AND EFFORT REPORTING CYCLE.
• ANYONE REPORTING EFFORT ON A CAP AWARD, WITH A UNIVERSITY SALARY GREATER THAN $183,300, WILL HAVE A MANDATORY COST SHARE REQUIREMENT FOR EACH EFFORT PERIOD.
• EXAMPLE: $200,000 UNIVERSITY 12-MONTH SALARY, WITH 15% MINIMUM EFFORT COMMITMENT AND MAX/CAP PAY IS $183,300/YR.
• 15% = $27,495 MAX PAY RATE, BUT• $27,495 = 14% UNIVERSITY SALARY, THEREFORE• EPAF SHOULD BE FOR 14% $$ EQUIVALENT AND• 1% WILL BE REQUIRED COST SHARE TO MEET THE EFFORT
COMMITMENT.
COST SHARE continued
• EXAMPLE: $200,000 UNIVERSITY 12-MONTH SALARY, AND MAX PAY IS $183,300/YR WITH 15% EFFORT COMMITMENT = $1,145/PAY PERIOD.
• EPAF PROCESSED AT UNIVERSITY RATE $200,000, IS $8,333/PAY PERIOD, 15% = $1,250/PAY PERIOD.
• AT EFFORT REPORTING TIME WITH 5 PAY PERIODS, TOTAL PAY SHOWING IS $41,666.
• ERS GRANT PAY IS SHOWING AS 15% OF SALARY AT $6,250.
• BUT MAX ALLOWABLE IS $5,725 ($1,145 X 5 PP). IN ERS YOU WILL NEED TO COST TRANSFER OFF $525 FOR A NEW TOTAL PAID OF $5,725.
COST SHARE continued• THIS WILL EQUATE TO 14% OF SALARY FOR THE EFFORT PERIOD.
• A 1% COST SHARE WILL NEED TO BE DOCUMENTED IN ERS TO MEET THE 15% EFFORT COMMITMENT.
• IF CORRECTING HR REDISTRIBUTIONS ARE PROCESSED BEFORE THE EFFORT PERIOD CLOSES ONLY COST SHARE WILL NEED TO BE PROCESSED IN ERS.
• DEPARTMENTS NEED TO REVIEW CALCULATIONS EACH ERS PERIOD AS THERE ARE DIFFERENT NUMBERS OF PAY PERIODS IN THE EFFORT REPORTING CYCLES.
• FOR INDIVIDUALS WITH MULTIPLE HHS CAPS, DEPARTMENTS WILL NEED TO MONITOR FOR DROP OFF DATES FOR THE “OLD” CAP AND START OF THE “NEW” CAP FOR INDIVIDUAL AWARDS.
9-MONTH SUMMER SALARY
• SUMMER SALARY FOR 9-MONTH FACULTY WILL ALSO NEED TO FOLLOW SALARY CAP REQUIREMENTS (IN ADDITION TO THE 133% RULE).
• MAX PER PAY PERIOD WILL BE $7,637.
• THE SUMMER EPAF MAY NEED TO BE LESS THAN THE NORMALLY CALCULATED 100% ACTUAL SALARY PER PAY PERIOD.
• EXAMPLE: $145,000 FOR 9-MONTH, 133% = APPX $8,056/PP = 100% IN SUMMER MONTH.
• ALLOWABLE MAX = $7,637/PP = APPX 93% OF UNIVERSITY SALARY RATE CALCULATION.
9- MONTH continued
• FACULTY NORMALLY CANNOT COST SHARE IN THE SUMMER BECAUSE THERE IS NO COST SHARE SOURCE.– CANNOT COST SHARE FROM SUMMER SESSION
TEACHING.
• SO THE SUMMER EPAF RATE MAY NEED TO BE LESS THAN THE NORMALLY CALCULATED 133% SALARY RATE.
• THE CAP COULD ALSO POTENTIALLY AFFECT SEMESTER BUYOUT CALCULATIONS FOR INDIVIDUALS WITH ANNUALIZED SALARIES GREATER THAN $183,300.
CAP/EPAF CALCULATOR
• ON THE OGC WEBSITE THERE IS A SALARY CAP CALCULATOR WHICH– PROVIDES COMPUTATION ASSISTANCE TO PROCESS AN
EPAF IN COMPLIANCE WITH THE CAP REQUIREMENTS AND– CALCULATES COST SHARE NEEDED WHEN COMPLETING
EFFORT REPORTING. GO TO– http://www.ecu.edu/cs-acad/grants/gc_forms.cfm– SELECT “SALARY AND SALARY CAP CALCULATORS
CAP/EPAF CALCULATOR• ON THE OGC WEBSITE THERE IS A SALARY CAP
CALCULATOR WHICH – PROVIDES COMPUTATION ASSISTANCE TO
PROCESS AN EPAF IN COMPLIANCE WITH THE CAP REQUIREMENTS AND
– CALCULATES COST SHARE NEEDED WHEN COMPLETING EFFORT REPORTING. GO TO
– http://www.ecu.edu/cs-acad/grants/gc_forms.cfm
– SELECT “SALARY AND SALARY CAP CALCULATORS
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QUESTIONS?
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