Summary of the NIH Notice of Salary Limitation on Grants, Cooperative Agreements, and Contracts
The NIH budget approved December 23, 2011 reduces the salary cap from Executive Level I ($199,700) to Executive Level II ($179,700). The lower level is effective with FY2012 awards where the initial Issue Date of the award is on/after December 23, 2011. For FY2012 awards issued on/before December 22, 2011 (competing and non-competing), the effective salary limitation remains at Executive Level 1, $199,700. See the NIH Salary Cap Summary and the time frames associated with salary caps.
Impact on proposals to be submitted to NIH submitted by UC Berkeley Principal Investigators: PIs should budget using projected salaries for the project period regardless of the new salary cap. NIH will adjust salary levels if necessary at the time of award.
NIH non-competing awards will not be recalculated to adjust for this decrease in the salary limitation. However, the level to charge for salaries on non-competing grants is dependent upon the issue date of the initial FY2012 award. For non-competing grants with initial issue dates on/before December 22, 2011, the applicable salary limitation is Executive Level I; for non-competing grants with an initial Issue Date on/after December 23, 2011, the applicable salary limitation is Executive Level II. For grants now limited to Executive Level II, unless otherwise restricted grantees may rebudget any funds freed as a result of the lower cap.
Questions & Answers 4, 5, and 6, excerpted below from the NIH Notice, provide information relative to re-budgeting for competing and non-competing awards.
4. A grant was issued on/after December 23, 2011. The award was based on the Executive Level I. Can I rebudget the funds awarded in excess of the new Executive Level II salary limit, or will NIH adjust the award by the difference between the two? It depends on the type of award. If the award is a non-competing award, then grantees may rebudget the funds awarded in excess of the new salary limit. However, if the grant is a competing award, the NIH IC will revise the award when an adjustment for the lower salary limit is needed.
5. Can grantees rebudget on FY2012 awards that were proposed using Executive Level I and are awarded on/after December 23, 2011? Executive Level II is effective with awards with an initial Issue Date of December 23, 2011 and beyond. For non-competing awards with an initial Issue Date of December 23, 2011 and beyond, grantees can rebudget. For competing awards issued on/after December 23, 2011, the ICs will revise the award and adjust the current and all future year commitments to apply Executive Level II when applicable.
6. For awards issued on/before December 22, 2011, will future year commitments be adjusted to reflect Executive Level II? For competing awards issued on/before December 22, 2011, no adjustment will be made to the FY2012 award; however, future year commitments will be adjusted when applicable to reflect Executive Level II. Non-competing awards will not be adjusted to reflect Executive Level II for either the FY2012 award or any future year commitments.
NIH issued several other notices related to FY2012 in the January 20 NIH Guide:
- Ruth L. Kirschstein National Research Service Award (NRSA) Stipends, Tuition/Fees and Other Budgetary Levels Effective for Fiscal Year 2012 (NOT-OD-12-033)
(National Institutes of Health, Agency for Healthcare Research and Quality, Health Resources and Services Administration)
- NIH Fiscal Policy for Grant Awards FY 2012 (NOT-OD-12-036)
- Notice of Legislative Mandates in Effect for FY2012 (NOT-OD-12-034)