Q1: What is the general rule for handling furloughs for individuals whose salaries are reimbursed, in whole or in part, by externally funded grants, contracts, or cooperative agreements?
A1: The general rule is that all UNLV employees, even those whose salaries are reimbursed by externally funded grants, contracts, or cooperative agreements will be required to take furlough, while post docs, graduate students, and students will not be subject to furlough.
Q2: What about UNLV employees, who are partially paid by a federal or other externally funded grant, contract, or cooperative agreement? How does the furlough program apply to them?
A2: An employee whose salary is partially funded from grants, contracts, or cooperative agreements shall be subject to Furlough Guidelines.
Q3: Is there a possibility to be partially exempt from furlough on sponsored programs, e.g. 100% funded on a project?
A3: At this time, no. There are active discussions being led by leadership with NSHE to address the impact on furlough on sponsored programs and an effort to reevaluate these concerns.
Q4: How should I prepare for these furloughs on my sponsored programs?
A4: Each PI should review their budgets and evaluate the scope of work, budget, and percent of effort based on the furloughed salary needed to complete the scope of work within the period of performance.
Q5: If I have other source of funds to pay for the reduced pay can I use those funds?
A5: No, the loss of salary due to furlough cannot be paid through other sources to make up that deficiency.
Q6: Who is ultimately responsible for the scope of work and any changes that need to be made with respect to the furloughs?
A6: The Principal Investigator (PI) is responsible for the technical, administrative, and fiscal management of a project. In addition, the PI is responsible for assuring that all costs are allowable, allocable, and consistent with the terms of an award. The Office of Sponsored Programs, Post Award Grant and Contracts will lend their expertise in making these determinations when requested to do so and will determine when prior approval from sponsor is required. The PI must endorse all charges to the grant including any adjustments to the budget.
Q7: What is the role of the Office of Sponsored Programs?
A7: The OSP Post Award Grants and Contracts research administrator assigned to your college/department should be consulted if there are any questions about whether under a specific agreement a prior approval form or notification to the sponsor is required. Post Award Grants and Contracts should be consulted when there is any uncertainty as to the flexibility of the award terms.
Q8: When is prior sponsor approval required?
A8: Any changes to the administration of an award that will adversely and significantly affect the scope of work require prior approval. Therefore, furlough related rebudgeting that is significant relative to the total budget and that results in a change in the scope of work, require notification to the sponsor. For National Institutes of Health awards, the determination is associated with rebudgeting of more than 25% of a budget line item.
The terms and conditions of any given contract or grant award govern the ability to re-budget project funds. Some awards are somewhat flexible, others are not. For instance, State awards do not generally allow for rebudgeting without prior approval. Many federal agencies issue grants and cooperative agreements under standard Research Terms and Conditions (RTC) based on Federal Demonstration Partnership (FDP) (expanded authorities.) Under this core set of administrative requirements prior agency approval for re-budgeting is typically not required. The following page provides guidance on prior approval requirements for FDP participating federal agencies. Please note that other federal agencies may elect to use the RTC terms on selective awards to their research recipients. The terms and conditions of the award will indicate when RTC conditions apply.
Re-budgeting that results in a change in effort on the project must be reflected in agency progress reports and should be adjusted, if applicable, through payroll allocation prior to work being conducted. This also allows for correct certification at the time of Effort Reporting. 3 For those federal agencies that have not adopted the standard RTC, and all non-federal agencies, the specific terms and conditions of the award will determine if re-budgeting to support additional effort is permissible and if sponsor prior approval is required. The OSP Post Award Grants and Contracts research administrator assigned to your college/department should be consulted for guidance.