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  • 1.  Non-Exempt Overtime Pay on Federal Projects

    This message was posted by a user wishing to remain anonymous
    Posted 09-14-2022 07:24
    This message was posted by a user wishing to remain anonymous

    The question at hand: Is it considered "allowable" or "unallowable" to pay a non-exempt employee overtime (OT) on a federally funded project? 

    Hello, I am new to Cayuse Connect, so I apologize if this is not the space to ask this question. However, I remember that this was intended to be a collaborative space for research administrators and I was hoping to get some input on a question that my department is attempting to answer.

    We are currently working on an NSF proposal, and, as part of the proposal, we want to include a non-exempt, part-time technician working additional assignment (i.e., they would be a current employee at our institution, but we want them to work some OT on the project).

    It is my understanding that, according to the Fair Labor Standards Act (FLSA), we are required to pay non-exempt employees OT. However, my boss is concerned that we are not allowed to pay OT in the context of federal grant funds. He quoted the Uniform Guidance, Section 200.430 h (2), which suggests faculty and staff are limited to their IBS rate. While researching this matter, I came upon the US DOL "Overtime Pay: Applicable Laws and Regulations" webpage, which also seems to have some helpful links regarding the issue. 

    Unfortunately, I am still pretty green in the research administration field and I sometimes struggle with understanding what it is these legal documents are truly getting at.

    Does anyone have any insight into this matter?


  • 2.  RE: Non-Exempt Overtime Pay on Federal Projects

    SUPERSTAR CONTRIBUTOR
    Posted 09-15-2022 06:43
    Overtime is (usually) an allowable expense.  Read the guidelines to see if it's specifically disallowed.  But silence is permission ;)  But those payments must also correspond to your institutional policies.  And remember to pro-rate the over-time according to effort towards the project.  Does that help?

    A

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    Andrea Buford
    Director, Office of Sponsored Programs
    Oakland University
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  • 3.  RE: Non-Exempt Overtime Pay on Federal Projects

    Posted 09-15-2022 11:49
    Hello Andrea!

    Thank you for your input on this matter. Your expertise is appreciated, and in line with everything I am learning from this and other discussion boards!

    Best,

    Laura

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    Laura Griglak
    Contracts/Grants Specialist
    Kettering University
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