As the principal investigator, you must verify that salaries and wages charged to sponsored awards are reasonable and reflect actual work performed by technical staff, students, and postdoctoral researchers. This salary verification is conducted quarterly at MIT.
Why It’s Important
OMB Uniform Guidance requires that MIT has a system for distributing and verifying salaries and wages charged to sponsored awards. When a PI manages a lab with multiple projects, the distribution of salaries must be carefully considered. MIT’s process for salary distribution and certification ensures that direct labor changes are reasonable and reflect the actual work performed. Salaries not certified within 90 days following the end of the quarter in which the costs were incurred will not be reimbursed by sponsors.
How to Comply
Your department, laboratory, or center administrator will advise you on its specific process for certification. In general, salary certification is the time to confirm that:
- all project personnel have been charged to the appropriate award.
- the effort of all project personnel has been appropriately distributed.
OMB Uniform Guidance requires that administrative and clerical expenses be normally treated as facilities and administration (F&A) costs, not as direct costs.
Why it’s Important
Administrative salaries and clerical expenses charged to sponsored projects that do not meet the criteria are subject to disallowance by MIT’s federal auditors.
How to Comply
MIT requires that administrative and clerical staff must be integral to a project in order to be direct charged to a federal award and must also be budgeted and justified or have prior written approval by the sponsor. To be integral to the project, the administrative activity should be:
- essential or vital to the project, and described accordingly in the justification;
- budgeted at a percentage of a person-month that reflects the essential nature (a minimum of 10% full-time employee (FTE)); and
- performed by individuals specifically identified with the project or activity.
Costs that are not also covered as indirect costs and questions regarding the appropriateness of administrative charges to federally-sponsored projects should be addressed to your local administrator or OSP representative.