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A. Proposal Requests More than Two Months’ Salary

If more than two months salary will be requested in a proposal, alert the OCG Proposal Analyst to that fact as early as possible in the proposal process. The PI will need to include additional justification in the budget justification and, potentially, the project description for the level of supported effort on the project. This can be done in any way that meets NSF guidelines and follows established ���ӽ紫ý procedures (see sample language in Section III.E). Examples of acceptable circumstances include:

• The project includes research faculty or research associates who do not receive a regular academic year salary from ���ӽ紫ý.
• A substantial level of supported effort is needed for the project to be successful (e.g., providing guidance to the project team on designing experiments, or survey or evaluation criteria).
• The PI is taking a lead role designing and conducting experiments intended to demonstrate the validity of the hypothesis being tested, or which move the project forward to the next milestone.��

The following are some questions to ask (or have the project team consider) when writing the justification for the increased level of effort:��

• Why and/or how is the additional salary support necessary to fulfill the project’s research objective(s)?
• How might the project be negatively impacted if the additional salary support for senior personnel is not included?
• Are there other ways (for example, hiring a postdoctoral researcher or additional graduate students) in which the effort necessary to fulfill the project’s research objectives might be secured, but that do not involve additional senior personnel salary support? If so, why is providing additional support to senior personnel better or more effective for the project?��

B. Proposal Requests Salary Support that Pushes Total NSF Salary Support above the Two-Month Limit��

If the amount of salary being requested on an NSF proposal would increase the total amount of salary for PIs and/or other senior personnel on the total of each individual’s NSF-funded projects to more than two months, alert the OCG Proposal Analyst to that fact as early as possible in the proposal process. The PI and the Proposal Analyst will need to provide additional information in the budget justification to include such details as the following:

• Demonstrate that the level of salary support requested for the new project is commensurate with the scope of the project.
• State that if funded, the PI’s and/or other senior personnel’s total salary across all funded NSF proposals would equal more than two months of the PI’s salary.
• Address the question of why the PI’s salary (or that of other senior personnel) on the project could not reasonably be reduced to the point where the total across all funded NSF projects would not exceed the two months’ salary limit.
• Address specific ramifications that would negatively impact the project if such a reduction of salary support would be required, and why these would not be reasonably addressed by increasing the amount paid to other project non-senior personnel (e.g., postdocs, graduate students) or other senior personnel whose effort across all of their funded NSF projects is less than two months.��

C. Earlier Proposals Requested Salary Support that Now Exceeds Two Months on All Active NSF Awards��

If the PI or other senior personnel have total salary support from all their active NSF awards that now exceeds the two-month limit, the proposed salary support can be charged to the project, but additional information may be required. If properly disclosed at proposal stage that the total salary support across all NSF projects is expected to exceed the two-month limit, no further action is needed. However, if that was not properly disclosed during the proposal submission stage, the PI or other senior personnel should contact the project’s OCG Grant Officer to complete an explanation for this salary support on the project to include such details as outlined in III.B above. The PI or other senor personnel should also notify their Proposal Analyst to ensure the new level of committed salary support is updated when submitting future proposals to NSF.��

D. Changing Salary Support Level After an Award Has Been Received��

If the amount of salary paid to the PI or other senior personnel on the project needs to be changed after the project has been awarded, notify the project’s OCG Grant Officer as soon as that becomes apparent. The change must be documented in OCG’s proposal and project records, the PI’s OCG Proposal Analyst must be notified, and/or the senior personnel’s current and pending support information for the project must be updated to reflect the new level of committed effort when submitting future proposals to NSF. Formal approval from NSF for this change is needed only if it also represents a change in the project’s objectives or scope, or if the change represents a decrease in effort of 25% or more of what was originally committed on any of the projects affected by the change.

Documentation for this change in salary support must be provided to substantiate its need. A budget impact statement, justification for a supplemental funding request, or justification for the change in salary support must address all of the following:��

• Describe why the additional salary support for senior personnel is needed to fulfill the project’s research objectives, or how the project would be negatively impacted if additional salary support for senior personnel is not provided.
• Describe how the costs proposed are reasonable, directly benefit the project, and represent a prudent use of NSF’s funds.
• Explain what other budgeted project costs will be reduced in order to compensate for the additional salary support for senior personnel, and why those reductions will not negatively impact the project or its scope of work.��

E. Samples of Justification Language��

The following are examples of language that can be used in justifying either a request for more than two months of salary on a single project, a request for salary on a project that would bring an individual’s total across all funded NSF projects to more than two months, or for rebudgeting after award to a level greater than two months of salary.��

“Due to the time-intensive nature of the work assigned to the PI [specify what that work involves], we are requesting salary commensurate with the level of effort required, and in excess of NSF’s normal allowance of two months per investigator designated as senior personnel across all funded NSF projects.”��

“Please note that the PI is a research faculty member, and, as such, does not receive an institutionally supported, 9-month academic contract with time allocated for research in addition to teaching duties. The total level of effort reflected here represents the minimum time needed to carry out the proposed scope of work.”��

“If the proposal is funded at the requested level, the PI’s total salary amount across all of her/his funded projects will exceed the two months normally allowed by NSF for senior project personnel. However, the level of effort requested on this project and all of the PI’s other funded projects represents the absolute minimum amount needed to complete the proposed scope of work for these projects. Any reduction in her/his effort to comply with the two-month rule would negatively impact her/his ability to complete the proposed work on time.”��

“The original intent was to hire a postdoctoral researcher [graduate student(s), etc.] to complete a portion of the proposed work. Despite all reasonable efforts, we have been unable to identify [hire, retain] an individual who possesses the necessary background and qualifications to carry out the proposed research. Therefore, in order to complete the approved scope of work on time, we propose to increase salary amounts for the PI and Co-PI X to level A and level B, respectively. Co-PI X also has a promising undergraduate student who is interested in this type of research, and the remainder of the funds originally allocated to support the postdoctoral researcher will be used to pay this undergraduate for a total of X hours at $XX/hour to carry out experiments under the direction of the PI and Co-PI X. No changes to the project’s approved scope or objectives will be necessary, and no other changes to the budget are contemplated.”