The presentation by Naomi Schrag of Columbia University and Joe Gindhart of Washington University in St. Louis, delivered to the Council on Government Relations in March 2015, explores the comprehensive changes and clarifications introduced by federal Uniform Guidance (UG) Section 200.430 regarding compensation practices at institutions of higher education (IHEs). The discussion centers on key themes such as the shift in terminology from “compensation” to “remuneration,” expanded recognition of the spectrum of federal and non-federal activities, and the clarification of allowable versus unallowable costs. The presenters emphasize the need for written institutional policies that satisfy federal requirements, with an insistence that costs must be reasonable, conform to policy, and be consistently applied.
The document addresses nuances in compensation, including institutional base salary (IBS), extra service pay (ESP), incidental pay, and incentive pay, stipulating under what circumstances each may be included or excluded in federal documentation. It highlights requirements such as not exceeding the IBS rate, the need for clear, written definitions of work covered, and the importance of robust internal controls and thorough documentation to support compensation charges. The presenters note that while budget estimates are permissible for charging federal awards, institutions must maintain systems that accurately reflect work performed, accommodate significant changes, and support after-the-fact reviews. Recognition is given to the complex, intermingled nature of faculty responsibilities in academic settings, for which the guidance allows some flexibility in precision. Overall, the presentation underscores the critical importance of compliance, transparency, and adaptive policy development to meet evolving federal standards in personnel expense documentation.
