Consultant payments on sponsored projects must represent compensation to individuals who are independent of the university and who render independent services. Consultant payments may not be made by faculty to colleagues where an employer/employee relationship exists. Rather, in these situations, colleagues should be compensated for services via the university personnel/payroll system according to percent effort of committed time; or donate their services as part of their intra-institutional collaboration as a professional courtesy. This expectation is part of the OMB Circulars A-21 and A-133.
On the whole, it is expected that consulting needs can be satisfied from resources within the university community. When outside consulting services are needed for a grant or contract, all of these conditions must be met:
- There must be evidence that the services provided are essential and cannot be provided by persons receiving salary support under the sponsored project.
- There must be evidence that a selection process was employed to secure the most qualified person available.
- There must be evidence that the charge is appropriate considering the qualifications of the consultant, normal charges, and the nature of the services rendered.
- Federal programs limit the amount per hour/day/annum that may be charged as a consultant fee. The rate can be found on U.S. Office of Personnel Management (OPM) Information on Federal Pay and Leave web page under the "Salary Tables." Unless specifically allowed in the agency guidelines, compensation should be limited to the amount for Executive Schedule Level I. The annual cap would be prorated for a daily rate by dividing by 352 and an hourly rate by dividing by 2088. Total annual compensation from all sources should not exceed this salary cap for any individual.
- If an outside consultant is employed, the individual must be established in the UWF Procurement and Contracts system as a vendor. Refer to the guidelines for the requirements for a Consulting and Professional Services contract (see Procurement & Contracts). If the third party is not eligible to be established as a vendor through this method, a subaward or subcontract agreement must be entered into with the individual’s normal employer for services and related costs. Refer to Subcontracting/Subagreement Agreements.