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Applying the NIH Salary Cap

  • The NIH Salary Cap is tied to the federal Executive Level I salary level.  Effective January 1, 2008 the federal Executive Level I salary level was increased to $191,300.
  • Remember that the NIH Salary Cap applies only to proposals being submitted to NIH, AHRQ or SAMHSA.
  • The Institutional Base Salary is to be used to calculate salary; the agency will adjust the awarded salary subject to the current salary cap at the time of award.
    • The PHS SF424 R&R application instructions state the following for detailed budgets:  for Base Salary, "Enter the annual compensation paid by the employer for each Senior/Key person.  This includes all activities such as research, teaching, patient care, or other.”  For UMB, this translates to Institutional Base Salary (IBS).  There is further clarification under the instructions for field name "Requested Salary”:  “Any adjustment for salary limits will be made at the time of award.”
    • Similarly, the PHS398 instructions require the Institutional Base Salary, and state that any adjustment for salary limits will be made at the time of award.
  • The annual inflation increase should be applied to the budget as usual.
  • In the Yes/No questions, check YES for the question about the sponsor’s salary cap.
  • After award, when the NIH releases a notice regarding an increase to the cap, the salary charged to the NIH project for investigators over the cap should be increased accordingly.

Question:  Do I still need to use the IBS if the funding opportunity has a limit on the amount of direct costs that can be requested?

Answer: 
You may enter the IBS as the Base Salary, but calculate the salary requested using the salary cap.  Explain this in the Budget Justification for each individual. 

In Coeus, when the IBS exceeds the NIH salary cap, calculate the appropriate percent of salary to charge to the grant.  First, multiply the Federal salary level ($191,300) times the actual effort that the investigator proposes to commit to the project.  Then, take that result and divide by the investigator's IBS.  Use the answer to that calculation as the % charged in the Personnel Budget Details ("Iron Man") screen, and use the actual effort as the % effort.

Example:  Investigator's IBS = $200,000.  Effort committed = 25%
.25 x $191,300 = $47,825
$47,825/$200,000 = .239125
Enter 23.91% under % Charged; enter 25% under % Effort
NOTE:  Coeus will add inflation as of 7/1 annually.

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