Policy: Minimum Effort on Federally Funded Sponsored Research Activities
|Date: 01/19/10||Policy ID: FIN-028||Status: Final|
|Contact Office:||Sponsored Programs|
|Oversight Executive:||Executive Vice President and Chief Operating Officer|
Academic Division, the Medical Center, and the College at Wise.
|Table of Contents:||
|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:||
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 policy FIN-027, Time & Effort Certification Policy.]
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). 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.]
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:
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.
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.
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.
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.
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.]
Roles and Responsibilities:
|Major Category:||Finance and Business Operations|
|Category Cross Reference:||Research Administration|
|Next Scheduled Review:||07/13/14|
|Approved By, Date:||Executive Vice President and Chief Operating Officer, 01/19/10|
|Revision History:||Updated 11/11/11, Revised 7/13/11.|
|Supersedes (previous policy):|