Compliance Reviews

The office of Grants & Contracts Accounting (G&C) conducts post-award compliance reviews to ensure good stewardship of the contracts and grants awarded to the university.

 

Salary Cap

A salary cap is the maximum compensation rate a sponsor will reimburse for a sponsored project. Amounts exceeding the salary cap should be designated as cost-sharing. At VCU, our Effort Reporting Team conducts periodic reviews to ensure compliance with Federal, state, and local sponsor guidelines and limitations.

To calculate the salary cap, it is important to review the salary in proportion to the established cap. Below is an example of calculating the NIH Salary Cap.

Example:

NIH Salary Cap as of January 2025 = $225,700

Dr. Brown has an annual salary of $300,000
NIH supports 20% of Dr. Brown’s salary (committed effort)
Salary Cap for Dr. Brown:
$225,700 * 0.20 = $45,140
$300,000 * 0.20 = $60,000

The difference between the two becomes the cost-shared effort ($60,000 - $45,140 = $14,860)
Direct Effort = $45,140/ $300,000 =15%
Cost-Shared Effort = $14,860/ $300,000 = 5%

Highly Sponsored Faculty

In accordance with our policy, the Effort Reporting Team periodically reviews effort statements with sponsored research to ensure a faculty member does not have more than 95% effort assigned to sponsored activities. When submitting proposals for new projects, it is imperative to consider non-sponsored activities such as proposal writing, teaching, office hours, and departmental duties when allocating effort. If a faculty member has or approaching more than 95% effort assigned to sponsored activities, it is important to reach out to the Division of Sponsored Programs (DSP) for assistance with proposals.

Faculty members with 95% or more effort assigned to sponsored activities must provide justification using the Highly Sponsored Faculty Memo. Please contact the Effort Reporting Team with any questions.

 

Effort Reporting Policy