FIN-028: Minimum Effort on Sponsored Program ActivitiesDate: 01/19/2010 Status: Final
- Roles and Responsibilities
- Compliance with Policy
Effective January 5, 2001 through a Presidential Review Directive and clarification memo issued by the Office of Management and Budget (OMB) to 2 CFR Part 220 (as codified from Circular A-21), it is expected that “most Federally-funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the Federal government. This effort can be provided at any time within the fiscal year (summer months, academic year, or both).” The clarification memo also states that, “… Some types of research programs…do not require committed faculty effort, paid or unpaid by the Federal government ...”
The National Institutes of Health (NIH) Grants Policy Statement notes that “‘zero percent’ effort or 'as needed effort’ is not an acceptable level of involvement for ‘key personnel'."
Any part of ‘University effort’ that is quantified and included in a sponsored program proposal and the subsequent award (e.g., two summer months, 12% time, one half of a year, three person-months, etc.). This quantified effort/time is associated with a specific dollar amount based on the employee’s Institutional Base Salary (IBS). Associated effort and funding to support this devoted effort/time can be in the form of:
Direct Charged Effort: Any portion of ‘committed effort’ toward a sponsored program activity for which the sponsor pays salary/benefits.
Cost Shared Effort: Any portion of ‘committed effort’ toward a sponsored program activity for which the sponsor does not pay salary/benefits, which instead are paid using other, non-federal UVa sources.
The portion of research costs that are not borne by the sponsors. Cost Sharing on research may be comprised of Voluntary Committed Cost Sharing, Voluntary Uncommitted Cost Sharing, or both.
Voluntary Committed Cost Sharing:
Sharing costs of a sponsored project when it is not required by the sponsor, but offered by the Private Investigator in the proposal budget or budget justification as a commitment to the project. When the proposal is awarded by the sponsor, the voluntary cost sharing commitment becomes part of a binding agreement and an award condition. Voluntary committed cost sharing must be tracked, documented and reported (when required) to sponsors.
Voluntary Uncommitted Cost Sharing:
Sharing costs of a sponsored project which are over and above proposed and awarded commitments. Such cost sharing does not need to be tracked, documented or reported to sponsors. For example, a key personnel committed to and charged 25% of the Institutional Base Salary to the project, but spent 35% of his/her research effort on the project. The additional 10% is voluntary uncommitted cost sharing.
Institutional Base Salary (IBS):
The annual amount that the University pays for an individual’s appointment, whether that individual’s time is spent on research, teaching, patient care, or other activities. Base salary excludes any income that an individual may be permitted to earn outside of the duties to the University. IBS includes both compensation for University-related effort and compensation from the University Physicians Group (UPG) for clinical effort.
Principal Investigators/Project Directors and Other Key Personnel:
Individuals whose effort is absolutely essential to the success of the proposed activity, either because of their critical leadership positions within the proposal (and consequently their intellectual guidance) or because of the uniqueness of the expertise they are contributing relative to the proposed scope of activity. ‘Key personnel’ typically include research scientists, principal scientists and senior scientists, depending on their intellectual contribution to the proposed scope of activity. Typically, replacement of any of these individuals requires approval from the sponsor. Importantly, the status of ‘Principal Investigator/Project Director’ and ‘key personnel’ does not necessarily imply salary support from the sponsor.
Sponsored Program Activities:
Externally funded programs under which the University is obligated to perform a defined scope of work according to specific terms and conditions and within budgetary limitations. These programs are to be budgeted and accounted for separately from other activities. Sponsored activities include grants, contracts, cooperative agreements, clinical trial agreements, Intergovernmental Personnel Agreements and other awarding instruments supporting research, instruction, public service, and clinical trials.
Any portion of ‘University effort’ devoted to a sponsored program activity that is not charged to the sponsor and that is above the amount committed in the proposal and the subsequent award. This ‘extra effort’ is neither pledged explicitly in the proposal nor included in the award documentation as a formal commitment. Principal Investigators/Project Directors and key personnel do no need to track uncommitted effort as cost shared effort.
All activities performed by a faculty or staff member that relate to their professional responsibilities regardless of how (or whether) the individual receives compensation are considered ‘total professional effort.’ All such activities are comprised of both inclusions and exclusions in defining 100% ‘University effort.’
The portion of ‘total professional effort’ that comprises one's professional/professorial workload at UVa, including the Medical Center and UVa at Wise, for which the employee is compensated (through UVa and/or the University Physicians Group - UPG). (See definition of Institutional Base Salary). This includes research, instruction, other sponsored program activities, administration, non-sponsored/departmental research, University service, competitive proposal preparation and clinical activities. For the purpose of effort certification, ‘University effort’ totals 100%, regardless of the number of hours worked or the individual’s appointment percentage. (For activities included and excluded from ‘University effort,’ reference Appendix A of policy FIN-027, Time & Effort Certification.)
In proposals and subsequent awards, Principal Investigators/Project Directors and key personnel must include some level of committed effort on sponsored program activities, unless specifically exempted by the sponsor or listed in Appendix A of this policy.
Effort commitments must be quantified in the proposal by using such methods as a percentage of time, dollar amount of salary, number of months, etc. These commitments can be paid from (1) the sponsored project and/or (2) other, non-federal UVa sources and must be based on the employee’s Institutional Base Salary.
The minimum amount of effort committed to a specific sponsored program activity may be no less than 1% of the employee’s ‘University effort.’ Beyond this minimum, the specific amount of effort committed to a particular sponsored program activity is left to the judgment of the Principal Investigator/Program Director, based on his or her estimate of the effort necessary to meet the technical goals and outcomes of the project.
[See Appendix A for examples of sponsored program activities that do not require a minimum level of committed effort by the Principal Investigator/Project Director and key personnel and therefore are not subject to this policy.]
Roles and Responsibilities:
Each individual involved in proposal or budget development and/or the management of sponsored activities is responsible for adhering to sponsor requirements as well as applicable University policies and procedures. Specifically:
- Communicating with unit administrators in the establishment of accurate and timely labor distribution schedules to ensure appropriate allocations of salary costs across various sponsored and non-sponsored activities.
- Committing effort on Federal and Federal flow-through sponsored research program activities when applicable and as deemed appropriate for the scope of work at hand. (For exceptions, see Appendix A of this policy.)
- Ensuring that all effort commitments (directly paid or cost sharing) are accurately reflected on the effort reports.
- Responding to any questions posed by reviewers regarding effort commitments.
- Reviewing for and advising faculty on the inclusion of effort commitments in Federal and Federal flow-through sponsored research program activitiess, as appropriate. (For exceptions,see Appendix A of this policy.)
- Providing assistance to individuals supported by sponsored program activities, to ensure that effort reporting accurately captures committed minimum levels of effort.
- Unit Labor Distribution/Scheduling Personnel, under the direction of the Principal Investigator/Program Directors, are are responsible for:
- Establishing proper/timely labor distribution schedules for persons supported from sponsored program activities to ensure appropriate allocations of salary costs.
- Adjusting labor schedules/performing labor distribution adjustments in a timely fashion in support of accuracy in salary allocations.
- Maintaining effective practices within the department/division to identify and capture effort on Federal and Federal flow-through sponsored research program activities in accordance with this policy.
- Reviewing effort commitments on proposals to confirm reasonableness of proposed effort.
- Maintaining effective practices to assist with proper and timely scheduling of labor distributions to ensure appropriate allocations of salary costs across various sponsored and non-sponsored program activities.
- Establishing and communicating policies and procedures related to minimum effort requirements.
- Assisting Unit Research Administrators and faculty in determining if there is a requirement of minimum effort on proposed sponsored research program activities, some of which may not be subject to this policy (see Appendix A of this policy).
- Reviewing proposals to ensure that minimum levels of effort commitments have been made according to this policy.
- Conducting periodic reviews of certified effort reports to support effort commitments (including minimum commitments) to sponsors.
Compliance with Policy:
Failure to comply with the requirements of this policy may result in the dis-allowance of expenditures by the sponsor; such expenditures will be transferred to a non-sponsored fund source. In addition, an individual’s failure to comply with the requirements of this policy may result in disciplinary action up to and including termination or expulsion in accordance with relevant University policies.
Questions about this policy should be directed to the Contact Office.