Major Changes in NIH Proposal Budgeting Policies

The NIH recently has made two significant announcements, one regarding the direct salary an individual may receive on NIH grants, and the other regarding cost of living increases.

The consolidated Appropriations Act, 2012 is restricting direct salary to the Executive II Level of the Federal Executive pay scale. This level is capped at $179,900.  The salary limitation refers to “direct salary” and “institutional base salary” and is exclusive of the appropriate fringe benefits and facilities and administrative expenses.  The executive II limit is effective for grants with initial issue dates of on/after December 23, 2011.

If you are unsure of the executive levels to use for your award take a look at the salary cap summary page provided here:

http://grants.nih.gov/grants/policy/salcap_summary.htm

For more information on the salary limit and a comprehensive Q&A section the full notice can be viewed here:

http://grants.nih.gov/grants/guide/notice-files/NOT-OD-12-035.html

In FY 2012, because the NIH is seeing a less than one percent increase in funding from FY 2011 levels, they are implementing a number of cost saving policies. One of these changes involves the inclusion of cost of living increases in future budget years.  According to the new policy, FY 2012 funding levels for non-competing awards will include no cost of living/inflationary adjustments. This policy affects all grants (research & non-research).

For future year commitments, inflationary adjustments will be discontinued for competing and non-competing research grants issued in FY 2012.  For awards already issued in 2012 the agency will revise the award amount in accordance with this new policy.

To learn more about the full policy please click on the link below:

http://grants.nih.gov/grants/guide/notice-files/NOT-OD-12-036.html

In both of these cases, JHSPH ORA recommends submitting budgets with actual costs, rather than cap amounts. Actual salaries can be listed, knowing that they may be cut in the event of an award. We recommend this because of the unpredictable nature of the federal budget. By the time your proposal is awarded, the cap may have been lifted, and you’ll be able to charge the full salary amount. Similarly, we recommend including all merit increases for salaries, and cost of living increases on other line items. When awarded, these items will simply be cut from your budget. The inclusion of these items will in no way negatively affect the peer review of your proposals.

In some circumstances, there may be a total value cap on the project. In those situations, departments may at their discretion limit salary to the cap amount and/or omit cost of living or merit increases to stay under the maximum award level. The bottom line is you won’t get it if you don’t ask, and asking doesn’t hurt. Other peer institutions are taking the same tack.