Compliance with Export Control Laws and Regulations
It is Boston College policy to fully comply with all applicable United States export control laws, regulations, and policies. To the extent possible, the University and its faculty and students will conduct academic and research activities in accordance with the exclusions and exemptions permitted under the applicable federal export-related regulations.
The regulations include the following:
Export Administration Regulations (EAR) implemented by the Department of Commerce:
The EAR covers the export of dual-use (civilian and military) items and technologies;
International Traffic in Arms Regulations (ITAR) implemented by the Department of State:
The ITAR covers the export of military and defense-related items, technologies and services; and
Department of Treasury, Office of Foreign Assets Control (OFAC) policies and regulations:
These regulations address country-specific controls, including economic and trade sanctions and embargoes, as well as restrictive controls with respect to specific entities and individuals. Travel and the transfer of funds, services, and items to certain countries and a designated list of entities and individuals are subject to OFAC regulations.
Export control regulations cover the oral, written, electronic or visual transfer of items, technology, software, services, and information outside the United States, or any such transfer of a controlled item with the intent to transfer to a non-U.S. entity or individual. It is important to note that transfers of technical data or disclosures of information within the U.S. (even to a foreign student or colleague at the University) may be a “deemed export” if the item or information is controlled under an export control regulation.
Deemed exports may occur in what would ordinarily be seen as normal scholarly discussion or equipment-sharing among colleagues. If a discussion or shared equipment includes controlled information, and the colleagues are foreign nationals, then additional care must be taken in ensuring that such disclosures do not violate the federal law and/or regulations.
Care must also be exercised when traveling to other countries. For instance, traveling with a laptop computer containing controlled information or certain encryption technology can violate regulations, particularly when traveling to certain countries on a federal embargo or restriction list.
The foregoing examples are by no means inclusive and are presented here solely for illustrative purposes. Federal export control regulations and policies apply to all Boston College employees and students, as well as those associated with the University on a temporary basis (e.g. visitors and visiting scholars). No person affiliated with Boston College may export items or make deemed exports contrary to the requirements of the aforementioned laws, regulations, or any policies and procedures the University may adopt to ensure the University’s compliance.
Most university activities and travel to foreign countries are not affected by export control laws, or they are subject to an exception. The most common exception applicable to a University’s transfer of technical data or information is the “fundamental research” exemption, which includes basic or applied research in science or engineering at an accredited institution of higher education in the United States in which the resulting information is published and shared broadly. Both to help ensure compliance with export control law and to protect academic freedom, University researchers should strive to ensure that their research activities meet this exemption whenever possible. Research will not qualify if the University accepts any restrictions on the publication of information resulting from the research (other than limited prepublication reviews by sponsors to ensure that their patent rights are not compromised) or the research is federally funded and specific access or dissemination controls regarding the resulting information have been accepted by the University or researcher. If the fundamental research exemption is not met, the University may need to adopt controls with respect to the research activities to ensure compliance with export controls, including any prohibitions on deemed exports within or outside the University. Furthermore, the fundamental research exemption does not apply to the export of licensed controlled tangible items or software or if the export is to an embargoed country or to a national of that country.
Export control laws, regulations, and policies are highly complex, and violations can result in severe civil and criminal penalties. Those seeking assistance in determining whether licenses are required or whether any restrictions apply to travel, exports or deemed exports should contact the Office for Research Integrity and Compliance (ORIC). Additional information and resources can be found in the Boston College Export Controls website: /research/exportcontrols.html. The ORIC Director is the responsible official for the University’s compliance with export control regulations and has been designated as the University’s “Empowered Official” in accordance with Department of State regulations.
Gift vs Grant Policy (Provisional)
The following policy is provided to provide clarity and guidance on the determination on whether an award should be classified as a gift or sponsored award.
A sponsored award is funding from an external entity such as a private foundation, corporation, or governmental agency for an activity with a defined scope and purpose undertaken by the University with the expectation of an outcome that directly benefits the provider.
Sponsored awards, which include both grants and contracts, bind the University to a set of specific terms and conditions and involve a related reciprocal transfer of something of value to the sponsor. In general, contracts contain a more precisely stated expectation of a definable work product on some set schedule as a condition of payment. Also, contracts generally provide for tighter control by the sponsor over the scope of work and utilization of funds.
The following factors are often indicative of a sponsored project:
- A line-item budget for the expenditure of funds for the project Activity
- A detailed statement of the planned Activity or scope of work
- A specified period of performance as a term and condition
- A commitment by BC to provide “deliverables” (e.g., products, or periodic technical or progress reports)
- Fiscal accountability, such as submission of financial reports, audit provisions, sponsor prior approval of or control over expenditures, and/or an obligation to return unexpended funds
- Obligation to convey rights to tangible or intangible property resulting from the project (equipment, data, technical reports, copyrightable or patentable materials)
Sponsored awards are charged facilities and administrative (F&A) costs, whether identified in the award or not, unless the sponsor has a written policy that precludes such recovery and the University has accepted the award with this restriction. The rates to be applied are Federally-negotiated or University-approved rates. The AVP (or designee) after consideration of the proposed award may choose to accept an alternative F&A cost arrangement.
Sponsored awards from private foundations, corporations, corporate foundations and government agencies are administered by OSP. The Corporate and Foundation Relations Office should be kept informed of all corporate and foundation activities and receive copies of all correspondence related to such activities.
No single indicator, by itself, distinguishes a gift from a sponsored project (“grant” or “award”). Gifts are unconditional, voluntary, irrevocable transfers of money or other assets to support University programs or activities. Gifts can be unrestricted or restricted.
The following factors are often indicative of a gift:
- Use of the funds is directly related to the University’s mission
- The value, if any, returned to the resource provider is incidental or nominal. Public benefits are not considered value returned to the resource provider
- The scope of work, budget, or period of performance is not specified by the donor or promised by the University
- There is no requirement to return unexpended funds to the donor
Depending on the facts and circumstances, some of the indicators listed above may be more significant than others; however, no single indicator is determinate of the classification of a particular transaction.
When the appropriate categorization of external funds received is uncertain, OSP, Advancement, and the Controller’s Office will be consulted before a determination is made. In cases of lingering uncertainty or dispute about the appropriate categorization of external funds received, the Provost and the University Financial Vice President will consult and reach a final determination.
Policy for Allocation and Use of F&A (Indirect Costs) Funds Returned to Departments, Centers, Institutes, Colleges, and Investigators
Facilities and Administrative (F&A) costs, also known as indirect costs, are those costs associated with sponsored projects that are incurred by the University which cannot be readily identified nor specifically attributed with a particular sponsored project yet support research endeavors.
To further support research a portion of the University’s F&A funds will be returned to the schools, departments and faculty to incentivize sponsored research activities and assist departments and investigators in ways that will enhance Boston College’s research enterprise.
Basis of the Allocation
The amount returned to each unit is 13% of the schools, departments and the investigator’s contribution from their sponsored programs F&A recovery. The calculation to determine the dollar amount to be distributed will be based on actuals and will lag one year. For example, the FY15 distribution will be based on FY13 actuals. The allocation will be divided evenly between the schools/departments and the investigators. When there are Co-PI’s, the VPR’s office will coordinate with the PI in the distribution to the Co-PI’s. Since each school is organized differently, the portion distributed between school and department can be modified at the Dean’s discretion only. In the event of an exemption to the above policy, e.g., a PI leaves the University, the Dean will work with the VPR to allocate the funds appropriately. Institutes and Centers not associated with a school will make alternate arrangements with the VPR.
Expected Uses for F&A Return:
Research incentives occur at several levels. The fraction returned to the investigator provides a means to purchase many shared items and costs that cannot be identified readily and specifically with a specific sponsored project. The funds pooled at the school and department level can support strategic initiatives or collective needs.
The following are some examples of appropriate uses:
- Common use items in the conduct of research such as, gloves, kim-wipes, other shared supplies, gases, laptops, ink for printers in the labs, lab notebooks, etc.
- Repair of research equipment and computers.
- Support for graduate and undergraduate research assistants or staff engaged in research activities.
- Research related travel for faculty or student researchers to attend professional meetings or to funding agencies.
- Support for activities related to obtaining additional funding such as proposal development.
- Membership in Research Societies, the purchase of research-related publications (books, subscriptions to research journals) and publication costs.
- Shared equipment that can’t be easily allocated.
- Travel costs to support speakers on research topics.
- Business meal expenses and meetings with research collaborators.
- A portion of the salary for fully funded researchers (100% on sponsored programs) if they write proposals.
- Supplement of Start-Up packages.
F&A Return Cannot Be Used For:
- Entertainment expenses not related to a research objective, e.g., group outings and holiday parties
- Purchase of alcohol must be approved by the Dean’s Office.
- Travel unrelated to research
- Donations to charity or organizations
- Teaching supplies or equipment unless it is part of a research project
- Academic year salaries for the Principal Investigator
- The return of F&A is a university investment not an entitlement. The expectation is that the administrators and the faculty will use these funds to enhance the research efforts of the university.
The funds do not carry forward to the next fiscal year; therefore, funds should be expended in a timely manner and will need to be fully spent within the fiscal year they are given. Investigator funds that are not 75% depleted or committed by March 1st of each year will be made available for use by their respective department.
1. Definition, Purpose, and Eligibility of Postdoc 6. Benefits
2. Appointment of Postdoctoral Research Fellow
7. Obligations of Postdoc
3. Terms of Appointment 8. Obligations of Faculty Mentors
4. Extension and Termination of Appointment 9. Appendix I
5. Stipend Level 10. Appendix II
NOTE: The full policy is available in pdf format for downloads.
Postdoctoral Research Fellow Policy
November 11, 2016
Boston College (“the University”) recognizes the importance of assisting
Postdoctoral Research Fellows (“Postdoc Fellows”) as they develop into independent
investigators. Postdoc Fellow appointments offer advanced degree recipients a period in which to extend their education and professional training. The breadth of the academic community together with the physical resources in its libraries and laboratories make the University an ideal environment for postdoctoral training.
While the University seeks to provide Postdoc Fellows with the opportunity to continue their academic training through on-site practice experience, many aspects of the relationship between the University and its Postdoc Fellows are also that of an employer-employee relationship. Therefore, the University has adopted this Postdoctoral Research Fellow Policy (the “Policy”) to delineate the obligations and expectations of all parties involved in Postdoc Fellow training. All Postdoc Fellows and Faculty Mentors must comply with the requirements set forth in this Policy. Any questions about the Policy should be directed to the University’s Office of the Vice Provost for Research (“VPR”).
1. Definition, Purpose, and Eligibility of Postdoctoral Research Fellow
1.1 Definition and Purpose: A Postdoctoral Research Fellow is an individual holding a doctoral degree or equivalent who is engaged in a temporary period of mentored research and/or scholarly training. The principal purpose of a Postdoc Fellow appointment is to acquire the professional skills needed to pursue an independent career path of the Postdoc Fellow’s choosing. A Postdoc Fellow is an employee of the University and shall work under the direct supervision and mentorship of the Faculty Mentor. The Faculty Mentor must hold a tenure-track position. Appointments primarily involve full-time research or scholarship and may include teaching responsibilities. See Appendix 1 for the Affordable Care Act’s guidelines on calculating teaching hours. The appointment shall be temporary (see Section 3 - Terms of Appointment).
1.2 Eligibility: To be eligible for a Postdoc Fellow appointment, an individual
must hold a Ph.D., M.D., J.D. or equivalent terminal degree from a recognized institution of
higher learning. Evidence of the degree must be provided to the VPR from the Faculty
Mentor. When a candidate has completed all of the requirements for a degree, but the
degree has not been conferred, the candidate may present evidence of completion of the
degree, together with a statement of the date on which the degree is to be conferred. If the degree is not conferred by the projected date, the Postdoc Fellow appointment shall be terminated. Candidates with non-U.S. degrees will be required to provide proof of degree equivalency as determined by each school at the University.
2. Appointment of Postdoctoral Research Fellow
2.1 Initiating Appointment: Individuals interested in a Postdoc Fellow appointment should directly contact the Faculty Mentor and the appropriate academic department in which the candidate is seeking the appointment. In advance of the initial appointment, the terms and conditions of that appointment should be discussed and agreed upon by the Postdoc Fellow and the Faculty Mentor. This should include agreement on the anticipated length of appointment, scope of work (e.g., research project), training goals, expectations of an annual research progress and mentoring (e.g., publication expectations, teaching, etc.), sources and amount of salary/benefits and research support, and possibly other details such as plans or expectations to submit fellowship applications, office space, lab, and supporting equipment such as computers.
2.2 Appointment Offer Letter and Approval Process: When a Faculty Mentor makes a decision to appoint, the Faculty Mentor will create an offer letter using the template approved by the VPR, found in Appendix 2. This offer letter shall be made prior to the commencement of duties. The offer letter must include the following:
The term, title, and schedule of the appointment;
Duties and responsibilities of the appointee;
Duties and responsibilities of the faculty mentor;
Period of appointment;
Level of support;
Source of support;
Stipend level and period of time for which funding support is guaranteed;
Statement of the expected obligations of the appointee during the training period;
Statement of teaching responsibilities, if any, associated with the appointment; and
A copy of this Policy.
The offer letter must be approved and co-signed by the Faculty Mentor, Department Chair, VPR, and Vice Provost of Faculties, if applicable. The VPR must approve the final offer if the Postdoc Fellow is to receive either grant or start up funds. The Vice Provost of Faculties must approve the final offer only if funding for salary, benefits, and/or research support is requested from the University or department. After all approvals have been obtained, the Faculty Mentor may then send the offer letter to the Postdoc Fellow.
The Postdoc Fellow appointee must acknowledge the terms of the appointment by signing and returning the offer letter to the Faculty Mentor. A copy of the final letter with all
signatures must be sent to the VPR.
3. Terms of Appointment
3.1 Full-Time Appointments: Individuals ordinarily hold Postdoc Fellow appointments on a full-time basis (40 hours/week) for no longer than four (4) years. The total term of Postdoc Fellow appointments may not exceed six (6) years including previous postdoctoral experience at other institutions. Extensions may be granted in exceptional cases (see Section 4.1, below) by the VPR and will be reviewed annually.
3.2 Part-Time Appointments: The University maintains that effective and meaningful training for Postdoc Fellows requires full-time commitment by the scholar and the University. As such, Postdoc Fellows at Boston College are ordinarily appointed in full-time status.
However, this Policy does allow for part-time appointments on a limited, case-by-case basis. If a part-time appointment is requested by the appointee, such request must be clearly stated in the offer letter, with the understanding that the appointee may perform and be compensated for additional University services or outside employment, up to but not exceeding full-time. Moreover, evidence must be provided that such a part-time appointment is consistent with the rules of the funding source and with the visa requirements of appointees who are not U. S. citizens or permanent residents. Part-time appointments must be approved by the VPR.
In instances where part-time appointment requests are approved, if the part-time appointee’s salary does not meet the minimum annual (non-FTE) salary required by the Fair Labor Standards Act (“FLSA”), then the Postdoc Fellow shall be classified as non-exempt. As such, the Postdoc Fellow will be eligible for overtime pay at one and one half time his or her regular rate of pay for all hours worked in excess of 40 in a week. For all hours worked in excess of his or her regular work schedule up to 40 in a week, the Postdoc Fellow will be paid his or her regular hourly rate. A work week is defined as Sunday to Saturday, based on the University weekly payroll cycle. All hours worked for each week will be submitted and tracked through the Kronos payroll system.
4. Extension and Termination of Appointment
4.1. Extension of Appointment: At the end of the term, the appointment may be eligible for extension based on satisfactory performance, the existence of funding, programmatic need, and continuing visa eligibility (for international scholars). Should the Faculty Mentor and Postdoc Fellow agree to extend a Postdoc Fellow appointment beyond the term defined in the initial offer letter, the Faculty Mentor shall submit a written request for approval to the VPR 60 days prior to the end of the appointment. Appointments can be extended on a yearly basis and will be reviewed annually by the VPR. In exceptional cases, the appointment may be extended beyond the six year limit, which is inclusive of postdoctoral experience at another institution.
4.2 Termination of Appointment: In the absence of extension, the Postdoc Fellow should assume that his or her appointment will terminate on the termination date set forth in the appointment letter. The Faculty Mentor and Postdoc Fellow are encouraged to hold regular, on-going conversations about the Postdoc Fellow’s transition out of the appointment. The VPR will conduct an exit interview at the conclusion of the Postdoc Fellow’s appointment.
If during the appointment the Postdoc Fellow is found to have violated the expectations detailed in this policy, the University may terminate the appointment prior to the termination date. In such instances, the Faculty Mentor shall consult with the Department Chair, the VPR, and Human Resources. These early terminations will be considered on a case-to-case basis. In the event of early termination, a written dismissal notice shall be issued to the Postdoc Fellow.
In instances where funding support for the appointment ends, the University may terminate a Postdoc Fellow appointment with 60 days written notice from the Faculty Mentor to the Postdoc Fellow. Finally, in instances of resignation, a Postdoc Fellow is expected to provide at least 30 days written notice to the Faculty Mentor.
4.3 Responsibilities at End of Appointment: Regardless of whether a Postdoc Fellow’s appointment ends due to resignation, lack of funding, or dismissal for cause, a Postdoc Fellow has certain responsibilities to meet at the end of appointment. First, it is recommended that the Postdoc Fellow work with his or her Faculty Mentor to submit research results, if any, for publication by the end of appointment, if possible. Second, the Postdoc Fellow must leave all original notes, computerized files, equipment, documents, and any other tangible materials in his or her possession with his or her Faculty Mentor prior to departure. Such materials and information are at all times the property of the University and the University retains the right to own, disclose, and use such materials and information at any time and for any purpose during and after the appointment.
The Postdoc Fellow may copy notes, computerized files, and other research materials that he or she helped generate during the appointment only with prior, written permission to do so from his or her Faculty Mentor and only if such reproduction is permitted under the terms of any applicable grant agreements or other contracts.
Moreover, future use of any such material and information by the Postdoc Fellow is limited by the terms of any applicable grant agreements or other contracts. Any confidential information obtained by the Postdoc Fellow during his or her appointment must remain strictly confidential and may be disclosed only in accordance with federal or state law, University policy, and the terms of any applicable grant agreements or other contracts.
5. Stipend Level
The University has formally adopted the NIH/NRSA guidelines as the minimum salary to be paid to Postdoc Fellows. The NIH/NRSA salary levels, which are adjusted annually, are based on the Postdoc Fellow’s years of research experience prior to the appointment. Should the FLSA dictate a minimum salary threshold for exempt status that is above the NIH/NRSA guidelines, the University shall use the FLSA minimum salary as the minimum salary to be paid to full-time Postdoc Fellows. Departments will be responsible for ensuring each Postdoc Fellow is paid at least the new minimum salary every year. For the projected NIH/NRSA guidelines, effective December 1, 2016, please visit the NIH/NRSA website: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-16-134.html
Boston College provides a broad and competitive range of benefits in order to promote the health and general well-being of its workforce. In addition to comprehensive health and dental insurance plans, the University offers many other benefits, including various types of insurance coverage, family and sick leave policies, tuition remission opportunities, and a generous number of paid holidays and vacation days. The following link (/offices/hr/resources/handbook/hbk-benefits.html) provides in detail the University’s benefits program. Further information is available from the Benefits Office at 129 Lake Street on the Brighton Campus.
7. Obligations of Postdoctoral Research Fellow
Postdoctoral appointments entail a mutually beneficial relationship between the Postdoc Fellow and the Faculty Mentor. This relationship engenders obligations on behalf of both the Postdoc Fellow and the Faculty Mentor. For the Postdoc Fellow, these obligations are to the Faculty Mentor, the laboratory in which he or she is working, the Department with which he or she is associated, the University, and the agency that supports him or her. These obligations include:
The conscientious discharge of research responsibilities,
Conformance to ethical standards of research,
Compliance with good laboratory practice,
Maintenance of laboratory notebook(s) and/or other records of research activity,
Adherence to University standards regarding use of isotopes, chemicals, infectious agents, animals, human subjects, and the like,
Open and timely discussion with the Faculty Mentor regarding all facets of the Postdoc Fellow’s research activities,
Prompt disclosure to the Faculty Mentor regarding the possession and desire to distribute materials, reagents, software, copyrightable and potentially patentable discoveries derived from the Postdoc Fellow’s research,
Collegial conduct towards members of the research laboratory and others,
Compliance with all applicable University policies and applicable terms of any sponsored agreement which provides support for the Postdoc Fellow, and
Completion of the Research and Scholarship Integrity Program within first two years of the Postdoc Fellow’s appointment.
8. Obligations of Faculty Mentors
The principal purpose of a Postdoc Fellow appointment is to acquire the professional skills needed to pursue a career path of the Postdoc Fellow’s choosing.
During the appointment, the Postdoc Fellow is expected to acquire the professional skills needed to pursue his or her chosen career path. The Faculty Mentor is expected to support and encourage the development of these skills by working with his or her Postdoc Fellow to develop a plan of research and goals for the appointment. Both the Faculty Mentor and the Postdoc Fellow must approve the plan. Other obligations of the Faculty Mentor include:
Provide adequate work and/or laboratory space and access to resources.
Hold annual one-on-one meetings that discuss professional development and mentoring.
Other encouraged practices by the Faculty Mentor:
Encourage Postdoc Fellows to seek secondary mentors who could provide them with opportunities in new areas of research, foster collaboration, and offer them guidance and support to assist with their career goals,
Seek the participation of these secondary mentors or multiple other faculty members in the annual progress reviews with their Postdoc Fellows,
Encourage Postdoc Fellows to participate in career development activities (workshops, courses, pre-conference events),
Recognize that because of the temporary nature of the Postdoc Fellow appointment, early encouragement of participation in career development activities is critical,
Encourage Postdoc Fellows to engage in social networking opportunities, such attendance at talks and seminars in the department or University-wide.
This policy seeks to set out infrastructure that helps the Postdoc Fellow acquire the skills necessary for a career of his or her choosing. It is intended to serve as a resource that protects all parties involved in the appointment. The VPR can be contacted if issues arise that are not addressed by the Policy or need assistance for resolution.
Appendix I: Determining Adjunct Hours of Service
The Internal Revenue Service has outlined two options for universities to determine the number of hours that adjunct faculty work when teaching in order for Universities to be compliant with the Affordable Care Act. Boston College has decided the “safe harbor” option is the most efficient method to calculate the hours needed in teaching a course. The Policy also uses this calculation when determining the teaching hours of Postdoc Fellows. Below is the calculation, which is based upon course credit hours and number of courses taught.
Postdoc Fellows will be credited with (a) 2.25 hours of service (representing a combination of teaching or classroom time and time performing related tasks such as class preparation and grading of examinations or papers) per week for each hour of teaching or classroom time (in other words, in addition to crediting an hour of service for each hour teaching in the classroom, this method would credit an additional 1.25 hours for activities such as class preparation and grading) and, separately, (b) an hour of service per week for each additional hour outside of the classroom the Postdoc Fellow spends performing duties he or she is required to perform (such as required office hours or required attendance at faculty meetings).
These hours are considered part of the Postdoc Fellow’s 40-hour work week.
Formula: (# of credit hours taught × 2.25) + # of classes
# of Credits (#) Classroom/Prep Credit (x 2.25) # of Classes (+) Total (=) % of Workweek (÷ 40 × 100)
1 2.25 1 3.25 8%
2 4.5 1 5.5 14%
3 6.75 1 7.75 19%
4 9 1 10 25%
# of Credits (#) Classroom/Prep Credit (x 2.25) # of Classes (+) Total (=) % of Workweek (÷ 40 × 100)
2 4.5 2 6.5 16%
3 6.75 2 8.75 22%
3 6.75 3 9.75 24%
4 9 3 11 28%
6 13.5 2 15.5 39%
9 20.25 3 23.25 58%
*For example, two single credit courses totaling two credits OR one two credit course and
one single credit course totaling three credits OR two three credit courses totaling six
The explanation and examples can be found in the letter from the American Association of Community Colleges. "IRS Releases Final Rule Concerning Treatment of Adjunct Faculty Under Affordable Care Act - Mostly Good News for Community Colleges." February 21, 2014. Accessed October 17, 2016.
Appendix II: Postdoctoral Research Fellow Offer Letter Template
Download the template as a Word Document by clicking the link above.
Research and Start-up Funds Policy
Faculty research and start-up funds are provided to support faculty in their research and scholarly activities. These funds cannot be used to supplement their salary unless explicitly allowed as part of the offer letter or granted as part of an endowed chair or professorship. Funds may be used for purchases of durable assets, such as computers, tablets, and other equipment, but they become university property and must be relinquished should the faculty member leave the University.
Start-up funds must be used within five years of hire, unless an extension is granted by the Provost and Vice Provost for Research due to, for example, medical or maternity leave.
Appropriate Use of Research and Start-Up Funds
The list below provides examples of expenses that may or may not be charged to research and start-up accounts. The faculty member is expected to use funds judiciously and in accordance with University policy. Start-up funds are not appropriate for personal use or any other expenses that are not directly related to research and scholarly activities. It is not possible to list all of the items and expenses that qualify or do not qualify as research or scholarly expenses. It is the purpose of the expenditure that determines whether it is a legitimate research expense. In the event of gray areas, faculty should seek guidance from their Chair or Dean.
Examples of Allowable Expenses
Travel costs to professional conferences and workshops
Professional conference registration fees
Professional journal subscriptions
Graduate or postdoctoral fellows/research assistant stipends or salaries
Research equipment/instrumentation and supplies
Research-related books and periodicals
Charges for core facilities (internal and external)
Computers and software
Research data acquisition costs
Examples of Inappropriate Expenses
Business or first-class travel
TSA pre-check fee
Home computers, internet and cell phone bills
Home or office furniture or office supplies/amenities
Gifts (for employees or non-employees)
Spousal, partner, or other family member travel costs
Gift cards (refer to BC policy on gift cards for exceptions)
Personal or summer salary
The purpose of this policy is to establish the definition of Institutional Base Salary (IBS) as to meet the requirements for sponsored programs’ proposal submission, and to meet the requirements of Federal government regulations: OMB’s Uniform Guidance, section 200.430 (h)(2) as it relates to effort.
This policy is applicable to all sponsored awards and must be followed by schools, departments, centers, institutes, and personnel of Boston College involved with sponsored awards.
The effective date of this policy is June 1, 2018
Institutional Base Salary (IBS) is the annual compensation paid by the University for an employee’s appointment whether that individual’s time is spent on research, teaching, administration, or other activities.
Institutional Base Salary Policy Details
IBS includes regular salary and compensation related to a second assignment (e.g., Appointment as dean, chair, and/or center director) if the second assignment is one year or longer in duration. IBS is based on the full work load for which the individual is compensated by the University regardless of the source of funding or the number of hours expended. The IBS does not include bonuses, one-time payments or incentive pay. Also excluded from the IBS is salary paid directly by another organization.
IBS does not include:
Bonuses, honoraria, and incentive compensation;
Summer supplemental pay for faculty with 9-months appointments;
Supplemental pay that may be issued for temporarily (not longer than one year) performing duties that fall outside of duties and responsibilities associated with the current appointment;
Fringe benefit payments;
Any income that an individual earns outside of duties performed for Boston College (e.g. consulting).
Note: Institutional Base Salary:
May not be increased as a result of replacing University salary funds with sponsor projects funds;
Is established by the University in an appointment letter, or other similar documentation, regardless of the source of funds;
Includes regular salary, as well as any second assignment (e.g., Appointment as dean, chair, and/or center director)
Institutional Base Salary on a Sponsored Projects’ Proposal
Institutional Base Salary must be used as the base salary on all sponsored programs’ proposals unless there is a statutory limit on compensation, such as the NIH salary cap.
When requesting salary support from a sponsor or providing effort on a sponsored project in the form of mandatory or voluntary committed cost sharing, the anticipated effort calculated in the form of person months or percent of effort must be based on the individual’s IBS. The portion of effort multiplied by the IBS will determine the appropriate dollars to request from the sponsor, or approved by the University if in the form of cost sharing.
Some sponsors may have a salary rate cap. Depending on the type of proposal submission the salary rate cap may or may not apply when preparing the proposal, but the salary rate cap will apply once an award is made.
If you have any questions about this policy, or need additional information, please contact the Office for Sponsored Programs main number at 617-552-3344 or directly contact your area’s OSP Liaison (OSP Staff).