Comment on FR Doc # 2013-02113

Time and accounting requirements should be different for those who fund a low percentage of their total salary from grants e.g. full time teaching faculty who typically only fund "summer salary" from grants. It should be acknowledged that even thought they may get paid for the month of July, they will likely do their one month's worth of work throughout the year. There is no way to express this truth without burdensome accounting. Should the University be required to distribute a single month of salary over the course of the whole year? 3 days in January, 6 in February, etc.? Under the current rules, if a faculty receives her/his salary during a single month writing a recommendation letter or attending a departmental meeting in that month would constitute a violation. This situation is very different from someone who works in a research institute and covers the majority of his/her salary with grants.