FIN-028: Minimum Effort on Federally Funded Sponsored Research Activities

Date: 01/19/2010 Status: Final
Last Revised: 11/11/2011
Policy Type: University
Contact Office: Sponsored Programs
Oversight Executive: Vice President for Finance
Applies To: Academic Division, the Medical Center, and the College at Wise.
Reason for 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.’

Definition of Terms in Statement:
  • Committed Effort:
    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 of the employee’s compensation. 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 activity for which the sponsor pays salary/benefits.
    Cost Shared Effort: Any portion of ‘committed effort’ toward a sponsored activity for which the sponsor does not pay salary/benefits, which instead are paid using other, non-federal UVa sources. 
  • Other Contributing Personnel:
    Other individuals included in a proposal (e.g., graduate students, postdocs, trainees, technical staff, other researchers, etc.) whose service is necessary to complete the proposed scope of work, but whose intellectual involvement is not required for the success of the sponsored activity.
  • 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 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. These activities are established as ‘G or Z’ awards in the University’s Integrated Financial System.

  • Total Professional Effort:

    All activities performed by a faculty or staff member regardless of how (or whether) the individual receives compensation. All such activities are comprised of both inclusions and exclusions in defining 100% ‘University effort.’ [Reference Appendix A of this policy for further details.]

  • Uncommitted Effort:

    Any portion of ‘University effort’ devoted to a sponsored activity 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.

    • For Principal Investigators/Project Directors and key personnel, uncommitted effort is not considered cost shared effort. However, the uncommitted effort percentage must be accounted for and documented as part of one’s 100% ‘University effort’ on the periodic effort report (See Procedure 8-31).
    • For other contributing personnel, uncommitted effort is considered cost shared effort and must be documented as such in Section I on the periodic effort report (See Procedure 8-31).
  • 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 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.)

Policy Statement:

In preparing proposals and in allocating effort after award, Principal Investigators/Project Directors and key personnel must include some level of committed effort on most Federal and Federal flow-through sponsored research activities, unless specifically exempted by the sponsor. Any effort devoted by these individuals that is above the committed effort amount is considered ‘uncommitted effort.’ Other contributing personnel should be included in the proposal reflecting their effort contributions to the project.

Unless specifically exempted by the sponsor, these 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 are paid from (1) the sponsor and/or (2) other, non-federal UVa sources. The effort commitments must be fulfilled within each year (summer months, academic year or both).

The minimum amount of effort committed to a specific federally sponsored research 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 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 Federal and Federal flow-through sponsored 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.]

  1. Roles and Responsibilities:
    The following offices and positions have roles and responsibilities in the documentation, recording and monitoring of minimum effort commitments.
    1. Principal Investigators/Program Directors and Faculty are responsible for:
  • Understanding and employing the principles and policy regarding minimum levels of effort on sponsored research activities.
  • Communicating with school/departmental 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 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 shared) are accurately reflected on the effort reports.
  • Complying with Sponsor requirements regarding any significant reductions (normally >25%) in effort commitments on funded sponsored activities.
  • Responding to any questions posed by reviewers regarding effort commitments.
  1. School/Departmental – Research Administrators are responsible for:
  • Understanding and employing the principles and policy regarding minimum levels of effort on sponsored research activities.
  • Reviewing for and advising faculty on the inclusion of effort commitments in Federal and Federal flow-through sponsored research programs, as appropriate. (For exceptions,see Appendix A of this policy.)
  • Providing assistance to individuals supported by sponsored activities, to ensure that effort reporting accurately captures committed minimum levels of effort.
  1. Labor Distribution/Scheduling Personnel are responsible for:
  • Establishing proper/timely labor distribution schedules for persons supported from sponsored 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.
  1. Department Chairs/Division Heads are responsible for:
  • Understanding and employing the principles and policy regarding minimum levels of effort on sponsored research activities.
  • Maintaining effective practices within the department/division to identify and capture effort on Federal and Federal flow-through sponsored research programs in accordance with this policy.
  • Reviewing effort commitments on proposals to confirm reasonableness.
  • 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 activities.
  1. The Office of Sponsored Programs is responsible for:
  • Establishing and communicating policies and procedures related to minimum effort requirements consistent with the January 5, 2001 clarification memo issued by the Office of Management and Budget.
  • Assisting School/Departmental Research Administrators and faculty in determining if there is a requirement of minimum effort on proposed sponsored research 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.

Time and Effort Certification, Procedure 8-31
Cost Share Contributions to Federally Funded Sponsored Activities, Procedure 8-32

Related Information:

VIII.C.1, Compliance with Sponsor Requirements
FIN-027, Time and Effort Certification

Policy Background:

This policy is currently under revision at the University. Although the statements herein reflect enforced policy guidance, please call the "Contact Office" listed above if you have questions about how this policy applies to your office. The statements herein are to be used as general guidance until the policy has been revised. Thank you.

Major Category: Finance and Business Operations
Category Cross Reference: Research Administration
Approved by, Date: Executive Vice President and Chief Operating Officer, 01/19/2010
Revision History: Updated 11/11/11, Revised 7/13/11.