National Science Foundation (NSF) Two Month Salary Limitation
The NSF Proposal and Award Policies Guide (Chapter II.C.2.g), states:
“As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget. Under normal rebudgeting authority, as described in AAG Chapters II and V, an awardee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long as that change would not cause the objectives or scope of the project to change. NSF prior approval is necessary if the objectives or scope of the project changes.“
Tufts University Compliance with NSF Two Month Salary Limitation
Tufts University has defined the year as September 1 to August 31. This policy applies to both direct NSF funding and NSF pass-through funding. It applies to all senior personnel, regardless of appointment type. Senior project personnel are defined as the Principal Investigator (PI), Co-Investigator, and other personnel listed in the senior personnel section of the budget.
Each faculty member with NSF support is responsible for their compliance with this policy. Research faculty whose effort across all NSF-funded awards will exceed two months in a year should note their appointment in each budget justification and explain why the additional effort will be necessary to complete the project as proposed.
Local Research Administrator (LRA) assists investigators with this policy by:
- Identifying senior personnel who are charging salary to NSF or NSF pass-through awards.
- Periodically calculate and review the total support that these individuals receive from NSF or NSF pass-through awards, cumulatively, during any one academic year.
- Confirm with the PI during proposal preparation if they foresee a need for any senior personnel to be paid more than two months’ total support across NSF-funded projects during any one fiscal year.