Salary Costs and COVID-19 Impacted Awards

This guidance provides clarification about the general allowability of salary costs for funding that benefits from sponsor flexibility for COVID-19 impacts and is subject to University policies related to COVID-19 impacts.

While this guidance applies to both federal and non-federal extramural awards, the terms and conditions of a particular extramural award take precedence. That is, if a sponsor does not allow the costs described in this guidance, a department must find another fund source.

Additionally, this guidance does not change the current terms and conditions of employee appointments, including appointment terms that expired prior to June 30, 2020.

Policy sources

There are three primary policy sources that frame this discussion:

• Federal agencies have issued guidance and statements generally allowing for flexibility and allowability of COVID-19 related costs, as long as these expenses are also consistent with the grantee’s institutional policies and federal costing principles.
• Interim Executive Vice President and Chief Financial Officer Paul Jenny issued guidance on March 24, 2020 about charging grants and contracts costs to Federal sponsored awards during COVID-19. It states “At this time, campuses should continue to charge salaries, stipends, and benefits to currently active awards consistent with the UC policy of paying salaries from all funding sources, federal and non-federal.”
• UC President Napolitano and the campus Chancellors issued a letter on April 2, 2020 stating that there would be no COVID-19 related layoffs through June 30, 2020, for career employees.

Options to keep position and remain eligible for pay

Current academic appointees and career staff employees will keep their positions and may be eligible for pay continuation. Employees should work with their managers and Human Resources. Payments made to the employee using any of these leave options may be an allowable expense under extramural awards, unless otherwise indicated by the sponsor.

• Remote Work. If the work can be accomplished remotely, there should be no change (the employees continue to receive their regular salaries).
• Scope of Work Changes. If impacts from COVID-19 mean a change in the scope of work, the PI should contact the campus C&G Office.
• Leave Options. If work cannot be accomplished remotely or an employee cannot work because of other complications (e.g., childcare issues or illness or caring for others affected by COVID-19), employees may use any of the appropriate leave options as applicable. These options are not listed in order of precedence. Employees should consult their supervisor and Human Resources to determine the appropriate leave option for their situation
  • 16 days of UC Expanded Paid Administrative Leave (PAL)
  • Accrued Sick Leave/Vacation Leave/PTO
  • Any of the two federal leave options specified under the Families First Coronavirus Response Act (FFCRA):
    • FFCRA Emergency Paid Sick Leave (EPSL)
    • FFCRA Expanded Family and Medical Leave (EFML)
  • Leave Options Exhausted. Once leave options have been exhausted, the campus should explore other solutions to maintain employment and pay, such as reassignment. Likewise, employees working on other tasks that are not related to a sponsored project that benefit from these combined flexibilities should be paid by other non-award sources. Reassignment to another sponsored project because the current project ran out of funds is not permitted.
  • Continued Pay Through September 30, 2020. Once applicable leave /reassignment options above have been exhausted, employees may be paid through September 30, even if they are unable to work for COVID-19 related reasons, provided they have met and documented all the following requirements:
    • They are a current academic appointee or career staff employee;
    • They are unable to work due to facility closures, curtailed operations or other university disruptions due to COVID19, and the employee is not be able to work on site or remotely in any capacity;
    • They have exhausted all applicable COVID19 paid leave options;
    • They have used 40 hours of vacation and/or similar leave accruals, such as PTO. This does not include sick leave. 
    • There are no other available funding sources; and
    • The PI has attempted to reduce overall operational costs.

 

New and Continuing Extramural Awards

A new extramural award should not be charged if it is known at the time of award acceptance that the scope of work cannot be performed. Additionally, no one should be added to an already active extramural award if the employee is unable to support the scope of work.

Effort and salary costs for employees already on an extramural award should only be adjusted in proportion to efforts to complete the scope of work. While federal agencies and other sponsors have extended flexibility to continue charging labor expenses when an employee is unable to complete work, charging such costs would only be appropriate if an employee had already contributed to the completion of an award. That is, it is inappropriate to transfer costs or increase the percentage of the FTE charged to an extramural award just because that award permits flexibilities.

If an extramural award benefits from these flexibilities at time of award acceptance, but later there is a COVID-19 impact, then the leave options would apply to the award as there was an intent to complete the scope of work at time of award acceptance.

Summer Salary

Those employees whose appointments permit Summer Salary paid for by an extramural award may not claim this additional compensation if work cannot be performed. Summer Salary is not a guaranteed benefit.  Summer Salaries are explicitly linked to a statement of work associated with a sponsored project. PIs should consult with their sponsor to see if there are opportunities to continue work and receive “summer salary” either through a different approach or with a revised scope of work.