From 2006 to 2010, the Office of Inspector General at the National Science Foundation conducted 16 audits of effort reporting systems at major research universities. The most common problems found in these audits are:
- Failure to adequately account for unfunded effort and voluntary uncommitted cost sharing
- Policies and procedures do not reflect grants management regulations and requirements
- Effort committed in grant proposal not charged to the grant
These audit findings are typically based on a January 5, 2001 Presidential Review Directive and clarification memo to Circular A-21 issued by the Office of Management and Budget (OMB), which states that “… most Federally-funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the Federal government.” In addition, 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.”
These audit findings plus OMB and NIH guidance make it important to establish and implement a minimum effort requirement. Therefore, effective immediately, the University of Massachusetts Amherst requires a minimum of 1% effort either directly charged or provided as pre-approved (Academic Year Salary Cost Share Approval Request Form) cost share on most grants.