Effort Reporting (ECC)

These types of activities can be charged to a sponsored project and count as effort:

• Directing or participating in any aspect of the research related to the specific project
• Writing a progress report for the project, sometimes called a continuation proposal
• Holding a meeting with lab staff to discuss the specific research project
• Activities contributing and intimately related to work under the agreement, including:
  • Participating in appropriate seminars
  • Consulting with colleagues about specific aspects of the project
  • Delivering special lectures about specific aspects of the ongoing activity
  • Attending a scientific conference held by an outside professional society to present research results
  • Reading scientific journals to keep up to date with the latest developments in one's field
  • Mentoring graduate students on the specific research project
• Making an invention disclosure, and some other activities related to pursuing intellectual property

The following cannot be charged to a sponsored project as effort:

• Proposal-writing, except for non-competing continuations (progress reports); this includes:
  • Developing necessary data to support the proposal
  • Writing, editing, and submitting the proposal
• Administration, including service as a department chair or dean
• Instruction, office hours, counseling for students, and mentoring graduate students on something other than a specific research project
• Service on an IRB, IACUC, selection committee, or other similar group
• Course or curriculum development not specific to the faculty member's research project
• Writing textbook chapters
• Fundraising
• Lobbying
• Work that falls outside of the definition of total UMass effort (see the complete definition in the Effort Glossary), such as:
  • Service as the primary editor of a journal
  • Peer review of manuscripts, regardless of whether compensation is received
  • Advisory activities for sponsors, including service on an NIH study section or NSF review panel, regardless of whether compensation is received

Faculty members, because of the scope of their activities associated with university effort, generally may not be 100% research. Academic staff may in some cases have their salary charged 100% to sponsored projects. However, charges to sponsored agreements may only include reasonable amounts for activities contributing to and directly related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. If the teaching and other activities are NOT contributing to and directly related to the work under the agreements that are paying the salary, then a portion of the individual's salary proportionate to the non-grant effort must be paid from other sources.

Generally, no. It would be very unusual for any grant or contract to allow funds to support a new grant proposal. While not all non-federal grants and contracts are subject to the same rules as federal grants and contracts, we are still bound by the cost accounting standards and the issue of consistency in how we classify costs. These costs are specifically noted in OMB Uniform Guidance as indirect and we must be consistent in classifying them as such. In addition, it could be viewed as a violation of our fiduciary responsibility to expend the non-federal sponsor funds in a manner that does not directly benefit the project they are intended to support.

The university applies a consistent practice of paying vacation and other accrued leave from the funding in place at the time the leave is taken. If grant funds are not being used to support the individual at the time leave is taken, the department will cover the leave costs. This is a fairly common practice at institutions and is viewed as acceptable because we are consistent in the application and do not discriminate between funding sources.

The effort certification process is conducted on a annual schedule for all faculty, including those on 9-month appointments. The certification period is from July to June. The rate of pay one can receive from a grant for work during the summer is based on the 9- month academic year salary rate. While summer salary is considered part of institutional base salary, it is generally a unique line or designation in the grant proposal.

For example, assume the 9 month salary is $3,000 per month for a full-time appointment and you commit 50% effort for two months during the summer. The rate of pay for those two summer months would be $1,500 per month for 50% effort per month.

Subject to the sponsor's rules, up to 33% of the AY salary for faculty on 9-month contracts.

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.

While it is important that the researcher maintains a good relationship with the Program Officer, this is not sufficient. Any decrease in effort greater than 25% by key personnel (as listed in the Notice of Grant Award) must be approved prior to the change and in writing by the sponsor's Grants Officer. The request must be processed through the UMass Amherst Office of Grant and Contract Administration in advance of the change.

An increase in effort greater than 25% for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored agreements. If there is a change in the scope of work, it must be approved prior to the change and in writing by the sponsor's Grants Officer. The request must be processed through the Office of Grant and Contract Administration in advance of the change.

Q: What are the effort requirements of a PI for a no-cost extension under Expanded Authorities? Does the original effort commitment extend to the no-cost extension period? Does the PI need to request permission to reduce his effort or does the institution have the authority to approve the reduction of effort when approving the no-cost extension?

A: Sponsors expect that the original award terms and conditions extend throughout the project period, including a no-cost extension (NCE) period. This would include commitments of effort for the Principal Investigator. That position has been voiced by federal grants officials in various settings and in response to specific questions about no-cost extensions. In addition, the January 2001 clarification to OMB Circular A-21 states that some effort should be provided by PIs on research awards; there is no exception for awards that are in no-cost extension periods.

However, there is also the realization by federal agencies that PI effort may be reduced during no-cost extensions as the project is winding down, or additional time is needed for data analysis. While this is not considered a change in scope, it is in the best interests of the institution and the PI to notify the sponsor of this decrease in effort to avoid discrepancies with current and pending support statements, effort certification or issues of research overlap.

K awards present a particular case as they generally carry the requirement for a 75% commitment of total professional effort. A reduction below 50% for a no-cost extension requires sponsor approval. The PI may, however, request that the sponsor approve eliminating or reducing the cost share during the no-cost extension process. While the University may approve the no-cost extension, the reduction of effort must be granted by the sponsor.

Unless the cost sharing is a mandatory requirement of the grant, the reduction can be taken from either the paid effort or the cost-shared effort.

The Effort Coordinator is a key resource to the faculty and the department in the effort reporting process, but they do not certify effort cards themselves. An Effort Coordinator can help verify that the percentages on the effort cards represents the submitted payroll allocations, that the correct personnel are on the sponsored projects, and that certifications are completed correctly and completely.

For each individual in the ECC system, a primary department has been assigned. The effort coordinator in your primary department will be responsible for helping you through the certification processes. It is possible that s/he will need to confer with the effort coordinator in your secondary department should any cost transfers be required.

In some situations the named Principal Investigator is not the person with the most suitable means of verification of effort for staff on the project. One example might be the PI of a large Center grant who has delegated the day-to-day operations of the Center to a Director or Manager. For that project, certification of staff effort is most appropriately handled by the Director or Manager, not the PI.

If you are named as a Key Person on the project and you have committed some level of effort in the proposal, you will need to participate in the effort certification process. However, because data in the ECC system is initially loaded from payroll, you may need to use a manual process for certifying.