Academic Affairs Manual (ACD)

Effective: 1/30/2008

Revised:

ACD 510–04: Intra-University Consulting

Purpose

To describe the policies and procedures applicable to intra-university consulting for faculty and academic professionals and to define the permissible extent of intra-university consulting activities undertaken for extra university compensation paid with state, local, sponsored, and other university funds

Sources

United States Office of Management and Budget: OMB circular A-21 (revised), Cost Principles for Educational Institutions (Section J.10.d)

Office of the Provost of the University

Office of the Executive Vice President, Treasurer, and Chief Financial Officer

Office of the Vice President for Research and Economic Affairs

Applicability

Faculty members

Academic professionals

Faculty members and academic professionals with administrative appointments

Policy

Federal regulations provide that intra-university consulting is expected such that extra compensation may only be granted in “unusual cases.” Specifically, OMB Circular A-21 J.10.d (1) provides that:

Since intra-university consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full-time base salary, the principle also applies to faculty members who function as consultants or otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution. However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his[/her] regular departmental load, any charges for such work representing extra compensation above the base salary are allowable provided that such consulting arrangements are specifically provided for in the agreement or approved in writing by the sponsoring agency.

Extra compensation for intra-university consulting is only paid in rare circumstances, regardless of the funding source. Similar to external consulting, intra-university consulting requires prior notification and approval using the Notification of Consulting or Other Remunerative Arrangement form indicating the source of university funds for compensating above the full-time base salary.

Intra-university consulting activity on behalf of a sponsored project requires the completion and approval by ORSPA of the ORSPA 310: Justification and Approval for Intra-University Consulting Pay form which would be attached to the Notification of Consulting or Other Remunerative Arrangement form prior to beginning the intra-university consulting. If a sponsoring agency allows supplemental pay for intra-university consulting then the university may allow such payments when all of the following conditions are met:

1. the sponsor specifically approves the extra compensation payment, in writing, or as provided for in the proposal and/or award document as intra-university consulting
2. the intra-university consultant is not an investigator on the sponsored project that requires the consultant’s services, subject to the provisions of paragraph 1 above, and OMB Circular A-21
3. the work performed is in addition to the employee’s regular workload and does not involve release time
4. the work for which the extra compensation payment is sought is performed for a department, center, or academic unit other than the employee’s assigned department or involves a separate or remote location, subject to the provisions of paragraph 1 above, and OMB Circular A-21
5. the payment is in accordance with ASU policy regarding supplemental payments found in the Academic Affairs Policies and Procedures Manual (ACD 510–01; ACD 510–02; ACD 510–03; ACD 510–04) and Staff Personnel Policies and Procedures Manual (SPP 404–02)
6. the work to be performed by the employee benefits the sponsored project during the project period

   and

7. the hourly rate of pay is consistent with the nature of the work being performed.

Extra compensation for intra-university consulting or outside consulting or other outside business activities or arrangements (whether compensated or not) shall not exceed 312 hours per academic year for those on academic-year contracts or 384 hours per fiscal year for those on fiscal-year contracts.

Employees whose assignment includes release time shall not normally be eligible for extra compensation. However, investigators and other employees performing work on a sponsored project usually can allocate part of their base academic or fiscal salary appointment to the sponsored project for work that benefits the sponsored project during the project period. General operating (state) funds released by such allocations are usually retained within the college or academic unit during the fiscal year as temporary salary savings.

Cross-References

For further information, see:

1. ACD 510–01, “Notification of Consulting or Other Outside Business Activities or Arrangements for Faculty and Academic Professionals Policy”
2. ACD 510–02, “Supplemental Pay”

   and

3. ACD 510–03, “Faculty Appointments for Other Than Fall and Spring Semesters.”

Also see the Staff Personnel Policies and Procedures Manual:

1. SPP 404–02, “Supplemental Pay”

   and

2. SPP 404–04, “Overtime—General Policy.”

 

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