NIH Salary Cap Guidance Changes

Page Updated: March 20th, 2017

Department of Health and Human Services (HHS) Salary Cap
The new salary cap impacts all HHS agencies, including NIH, CDC, FDA, ACF, CMS, HRSA, AHRQ and SAMHSA. At this point, we have only received guidance from NIH on how to implement the cap. We will provide any additional HHS agency guidance as it is provided. In the meantime, the University is following NIH guidance for all HHS agencies.

The NIH has issued salary cap guidance. Please read the notice carefully. Below is a high-level summary.

  • Competing grant applications and contract proposals that include a categorical breakdown in the budget figures/business proposal should continue to reflect the actual institutional base salary of all individuals for whom reimbursement is requested. In lieu of actual base salary, however, applicants/offerors may elect to provide an explanation indicating that actual institutional base salary exceeds the current salary limitation. When this information is provided, NIH staff will make necessary adjustments to requested salaries prior to award.
  • The salary limitation does NOT apply to payments made to consultants under an NIH grant or contract although, as with all costs, those payments must meet the test of reasonableness and be consistent with institutional policy.
  • The salary limitation provision DOES apply to subawards/subcontracts for substantive work under an NIH grant or contract.

Fed FY 2017

Cap Change Date: January 8th, 2017 - $187,000; January 10th, 2016 - $185,100

Fed FY 2016

Cap Change Date: January 10th, 2016 - $185,100; October 1st, 2015 - $183,300

Fed FY 2015

Cap Change Date: January 11th, 2015 - $183,300; October 1st, 2014 - $181,500

Fed FY 2014

Cap Change Date: January 12th, 2014 - $181,500; October 1st, 2013 - $179,700

  • All funds issued prior to January 12th, 2014 may be re-budgeted to allow for the rate increase.
  • A prorated figure of $180,861 will be used for the month of January.
  • Any remaining funds at the UW still subject to Executive Level I are not impacted by this change.

Fed FY 2013

No Cap Change - $179,700

Fed FY 2012

Cap Change Date: December 23rd, 2011 - $179,700; October 1st, 2011 - $199,700

  • Implementation of the lower level salary cap (Executive Level II $179,700) is effective with FY2012 awards where the initial Issue Date of the award is on/after 12/23/2011. For FY2012 awards issued on/before December 22, 2011 (competing and non-competing), the effective salary limitation remains at Executive Level I ($199,700)
  • NIH competing grant awards with an initial Issue Date on/before December 22, 2011 with categorical budgets reflecting salary levels at or above the new limit may continue to apply the Executive Level I salary levels for the FY2012 award period. No adjustments are required. However, future years for these awards will be adjusted to reflect Executive Level II.
  • For non-competing grants with initial Issue Dates on/before 12/22/2011, the applicable salary limitation is Executive Level I; for non-competing grants with an initial Issue Date on/after 12/23/2011, the applicable salary limitation is Executive Level II.
  • Any grants awarded in previous fiscal years (e.g., FY 2011, FY 2010, etc.) are not impacted by the FY 2012 salary limitation. Carrying over previous years' funds to support salaries will remain at the salary limitation levels in effect at the time those awards were issued.
  • If a grant was issued on/after December 23, 2011 and it is a non-competing award, then grantees may rebudget the funds awarded in excess of the new salary limit. However, if the grant is a competing award, the NIH IC will revise the award when an adjustment for the lower salary limit is needed.