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titleAbout This Policy


Effective Date: January 6, 2020

Responsible Office: Office of Research Strategy & Innovation and Office of Finance

Responsible Officer: Vice Dean for Research Strategy and Innovation and Vice Dean for Finance and Administration

Policy Contact:

Gary W. Miller

Vice Dean for Research Strategy and Innovation

gm2815@cumc.columbia.edu

Sepi Sepasi

Vice Dean for Finance and Administration

ss5827@cumc.columbia.edu



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NIH Over-the-Cap Salary Cap Policy Financial Guidelines


The US Congress has legislatively restricted the amount of salary an investigator can charge to sponsored projects awarded by the National Institute of Health. Investigators that earn more than $192,300 (“NIH-Salary-Cap”) must supplement salary with additional non-federal funds in order to earn his or her full wage.



This policy outlines the financial responsibility for supplemental salary as it relates to the NIH-Salary-Cap.


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As with all other operating expenses at Columbia Mailman, expenses attributed to the NIH-Salary-Cap are assigned ownership and responsibility according to the following framework:


 

ORDINARY

EVENT-DRIVEN

SPECIAL CIRCUMSTANCES

Description

Normal operating expense required for unit operations

Irregular expenses due to not following established policy; cost of doing business

Unforeseeable and/or random expenses that result from new or evolving policies

Responsibility for Expense

Operating Unit
Operating Unit
Operating Unit and Central Administration


 Example

  • Faculty/staff salary
  • Office or Research Supplies
  • FAIR Charges
  • Audit findings/unallowable costs
  • Sponsor penalty
  • Overdrafts
  • Exchange Rate settlements
  • EEOC settlements
  • Lawsuits

 



There are three basic types of cost in the framework. The first type of cost are ordinary expenses, such as faculty or staff salary, non-compensation costs, or FAIR charges and they are the responsibility of the originating unit. These expenses are predictable and derived from regular and ongoing operations. 

 


The second type of cost are out-of-the-ordinary or event-driven expenses. Although these expenses are unplanned, the majority result from not following policy and therefore are the responsibility of the unit. Audit findings, penalties, and/or overdrafts are examples of event-driven costs. 


The third type of cost are irregular or costs that arise from a special circumstance. If a unit is following policy but policy changes, then the unit and Central Admin are both responsible for the cost. These types of costs are completely unknowable and are not the fault of either the unit or Central Admin. Units should not bear the cost of random expenses alone.

 

Expenses related to the NIH-Salary-Cap are an example of an ordinary expense resulting from regular and ongoing operations. Therefore, units are responsible for funding and paying all NIH-Salary-Cap expenses in their respective units.



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