They should certify their actual effort, up to the sum of their paid and unpaid commitments. They should NOT report effort that is ABOVE the sum of their paid and unpaid commitments because that effort above the committed level is voluntary uncommitted costs-sharing, and it does not have to be documented.
Example: Dr. X is paid 10% on a sponsored project and has an additional cost-sharing commitment of 5% of his effort. If Dr. X worked 15% of his time on the project, we want him to certify 15%. If he worked 20% on the project, we want Dr. X to certify 15%.
This gets back to the purpose of effort certification, which is: to provide assurance to the sponsor that the researcher has met his/her commitment. "Extra effort" is uncommitted cost sharing and is not tracked, and is not auditable.
Effort related to review panels or other advisory activities for federal sponsors, whether you are reimbursed or not by the federal agency, is not included in your total effort for effort reporting purposes.
These types of activities are considered to be administrative or instructional in nature and are part of your nonsponsored activity. They cannot be charged to a sponsored project, though in a few instances the effort associated with an activity may be so small as to be considered de minimis.
Infrequent, irregular activity that would normally be considered "so small" that it is not statistically significant is called de minimis effort. Activities can be considered de minimis in amount when, in the aggregate, they represent less than one percent of the individual's total University of Massachusetts effort.
Depending on the nature and extent of the activity, and on the amount of time it requires in an effort period relative to the individual's total University of Massachusetts effort for the period, the types of activities that may qualify as de minimis effort include service on ad hoc committees, participation in department and division meetings, and other basic activities of University life.
Grant proposal writing and well-defined, regular administrative activity cannot be considered "so small," and therefore must not be treated as de minimis activity.
Faculty should consult with their department administrator and chair to determine the source of funding for non-grant activities. Generally, any departmental/school sources, including but not limited to general operating funds, gifts, endowments, etc., may be used to fund these activities. Departments and colleges are responsible for assuring that provisions for funding are in place. It is not a function of the effort reporting process to monitor or certify that funding is available. The effort reporting process is simply the mechanism that allows faculty and staff to provide assurance that the compensation paid from grants and contracts is reasonable in relation to the effort expended on those agreements.
The following areas are receiving significant attention nationally:
- 100% research faculty - are they involved in activities that should be funded by sources other than their grants?
- Faculty with 5 or more federal awards - are they overcommitted? Are the percentages of salary distributed to each of their projects reasonable?
- Change in Level of Effort - are faculty seeking permission to change the level of effort proposed in their grant when required (typically when the change is 25% or more)?
- Faculty with 1 or 2% of their effort on many awards - are they contributing the effort promised?
- Faculty Effort Certification - is it timely?
- Retroactive Salary Cost Transfers - are they infrequent, but timely when necessary? Of particular concern are those affecting time periods for which faculty have already certified their effort.
- Total effort commitments (paid and cost shared) to the sponsor - are they met?
- University effort reporting policy - is it being followed?
NIH grants now have an "Other Significant Contributors" field available. This allows the PI to identify individuals who have committed to contribute to the scientific development or execution of the project but are not committing any specified measurable effort. The following is a quote from the NIH 424 (R&R) instructions: "OSCs are individuals who have committed to contribute to the scientific development or execution of the project, but are not committing any specified measurable effort (in person months) to the project. These individuals are typically presented at effort of zero person months or as needed (individuals with measurable effort cannot be listed as Other Significant Contributors). Consultants should be included if they meet this definition. This would also be an appropriate designation for mentors on Career awards."
Q: I am currently a faculty member at University of Massachusetts. I often tend to work 50 or sometimes even more hours per week. The precise number changes from week to week and month to month and reflects the uneven nature of research, teaching, and administration. It appears to me that the admission of working extra hours can only penalize the individual. As an example, faculty members A and C receive the same amount of money from the grant ($37,500) and perform the same number of hours' work (10 per week), yet because C works longer hours, he/she is apparently receiving too much from the grant, and should in fact receive less ($25,000) for the same amount of work. It seems therefore that all faculty members should take care not to work more than their allotted hours per week. Am I correct in making this conclusion?
A: The university does not specify the number of hours per week a faculty member must work. There is an expectation that members of the faculty will work the hours necessary to carry out the professional responsibilities of their position. There is also the realization that the number of hours required for any activity will change over time. That's one of the reasons effort reporting is based on a percentage of effort rather than a number of hours.
Faculty appointments generally specify an annual salary amount that is negotiated between the department/college and the individual faculty member. That rate of pay covers all the activities you perform for your department - research, teaching, outreach, public service. Sponsors expect that the salary charged to their project for the effort performed will be at the same rate as the salary charged to other activities performed by the faculty member.
Effort on grants is to be based on your total university effort. The principle is that sponsors are not to be charged at a higher rate per unit of effort than the institution pays an employee for effort directed towards other university activity. The percent of salary allocated to your grant should be commensurate with the percent of your total university work effort, directed towards the goals of the grant. This principle demonstrates that regardless of the activity engaged in for the university the compensation for that effort is at a consistent rate.
No. This is called voluntary uncommitted cost sharing and is a contribution of non-sponsored effort. It is not auditable and does not need to be reported.
The committed effort not funded by the grant becomes a cost sharing commitment.
For example, a faculty member notes 20% effort on a proposal with requested funding for the full 20%. After the proposal is awarded, the PI discovers a need to reduce his/her compensation from the award (gets paid at 15% from the award) but does not reduce his/her effort committed to the award (still at 20% effort). This creates a 5% cost sharing situation which should be documented on the effort statement and in the cost sharing system.
