Time & Effort - FAQs
Frequently Asked Questions
- What types of activities can I charge to my grant?
What is effort reporting?
Effort reporting is the federally-mandated process by which the salary charged to a sponsored project is documented as being reasonable in relation to the effort expended on that project. Discussion: During the course of the year, the university charges salaries to sponsored projects and other accounts based on allocation instructions (i.e., the percentage of salary to be charged to one or more sponsored projects or other accounts based on committed effort) provided by academic department personnel acting upon instructions from Principal Investigators and others who oversee those sponsored projects. Federal regulations and university policy require that throughout the course of the year, these charges be monitored to ensure that any significant change in effort or workload results in a change of the salary distribution.
Who is required to certify?
All faculty members who receive any portion of their salary from a sponsored project, or otherwise provide effort on a sponsored project, must self certify their effort. In addition, a Principal Investigator is required to certify the effort of other staff who devote effort to his/her sponsored project.
Why can’t a departmental administrator certify my effort for me?
University policy requires faculty to certify for themselves and their project staff. In addition, Federal regulations require a certification that the salary charged is reasonable in relation to the effort expended. The regulations further require that the certification be signed by the principal investigator. The university has determined that best practices dictate that faculty self certify their sponsored effort. In addition, a Principal Investigator is now required to certify the effort of others charged to his/her sponsored project.
How often must I certify my effort?
You are required to certify shortly after the conclusion of each fall, spring, and summer semester. There is a 30-day period of time during which the certification process may be done. You will be notified by e-mail when the certification period begins and the date by which the certification must be completed.
How precise must my effort be?
Federal regulations clearly acknowledge that precise determinations are not expected, and that reasonable estimates are acceptable. To quote directly from OMB Circular A-21, "It is recognized that, in an academic setting, teaching, research, service and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate." Consistent with the Federal regulations, the university requires you to use your best judgment in your certification, taking into consideration all of the sponsored activities--federal, state, or private--that you were engaged in during the course of the fiscal year.
If I need to reduce the effort on (and therefore the salary charged to) my sponsored project, where will the funding for that non-sponsored effort come from?
Funding for non-sponsored activities such as teaching, administrative activities (including proposal writing as described above), as well as cost sharing on sponsored activities must be charged to non-sponsored sources (i.e., departmental funds). Under no circumstances may the costs associated with these activities be charged to sponsored projects; funding for these activities is a departmental and/or College issue and you should discuss this with your Chair and/or Dean.
I didn’t know about these effort rules when I filled out my grant application. Is it too late to fix the problem now?
No. If you have concerns about your grant application, contact the Office of Research and Sponsored Programs.
What types of activities can I charge to my grant?
These types of activities can be charged to a sponsored project:
- 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
What activities cannot be allocated to my sponsored project?
The following cannot be charged to a sponsored project:
- 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
- Work that falls outside of the definition of total UML effort 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
I am an administrator, and am unclear about whether we want our researchers to certify their payroll or their actual effort?
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.
For purposes of effort reporting, what does "instruction" mean?
"Instruction" means the preparation, evaluation, and delivery of teaching and training activities of the University, regardless of whether offered on a credit or non-credit basis. It also includes instruction-related activities such as thesis advice, mentoring of students and similar activities. Effort related to instruction is included in a faculty member's total UML effort. It excludes continuing education activities.
What about mentoring of students that relates to a faculty member's sponsored research?
Mentoring of students related to a sponsored research project is appropriately included in effort directly charged to a faculty member's sponsored agreement. OMB Circular A-21 states that charges to sponsored agreements may include reasonable amounts for activities contributing and intimately 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.
For purposes of effort reporting, what does "administration" include?
Administration includes effort incurred for services that benefit common or joint university or departmental activities or objectives in deans/chancellors' offices, academic departments or programs and divisions, and organized research units. Proposal preparation is also included in administration, and therefore cannot be charged to federally sponsored projects.
Is effort that is related to service on review panels or other advisory activities for federal sponsors included within my total University effort?
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.
How do I classify effort related to thesis committees, search committees, faculty senate committees or activities, compliance committees, and similar activities?
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.
I am an academic staff member and work 100% on a sponsored research grant. I am also on a UMass Lowell committee, an activity on which I spend a few hours a year. Is that ok?
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 UML 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 UML 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.
What risk areas should we focus on as a college or department?
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?
Is effort related to pursuing intellectual property (e.g. making an invention disclosure, meeting with CVIP to discuss an invention disclosure, reviewing internal action on a patent application and/or reviewing a draft patent application) on UMass Lowell awards included within my total University effort and can it be directly charged to grants?
Yes, consistent with the spirit of Bayh-Dole, reasonable levels of activity related to pursuing intellectual property can be charged directly to the appropriate grant. As with any effort charged to sponsored agreements, effort associated with the pursuit of intellectual property must be directly related to the sponsored project that is being charged. Where more than one award or activity contributed to the development of the intellectual property, the effort distribution should be based on proportionate support provided under the awards or other equitable relationship. The effort must also occur within the award period. These activities should be included within total University effort for effort reporting purposes.
Is there a minimum level of effort required for key personnel in grant applications?
In keeping with federal policy, it is the UML's policy that all PIs must have some minimal commitment to the sponsored project, i.e., 10%. NIH also requires that all key personnel have a measurable commitment to the project. While many sponsors will allow key personnel other than the PI to have no measurable effort on a project, it is advisable to quantify the commitments of all key personnel.
Can a faculty member be noted as contributing to a grant without committing effort?
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."
I am currently a faculty member at UMass Lowell. 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?
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.
How is my effort preparing my next grant proposal funded?
During the effort reporting period in which you prepare the proposal, the percentage of your effort spent on proposal preparation must be funded by University sources other than sponsored projects. However, if you are writing a progress report or a request for non-competing funding, those activities may be appropriately charged to the sponsored project.
What if there is a 100% researcher and s/he is going to apply for a new grant? How is that person to be paid for the time that will be devoted to preparing the proposal?
A portion of salary consistent with the effort needed for preparing the proposal should be paid from non-federally funded sources, including PI overhead return during the period when the researcher is writing the proposal The percent should be consistent with % effort spent on proposal preparation.
What if that same person teaches or is involved in other scholarly activities and is 100% funded for research. Is that okay?
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.
Can a faculty member use a non-federally sponsored funding source (i.e., foundation dollars) to cover their grant writing effort?
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 Circular A-21 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.
Is it sufficient for a faculty member to simply tell his/her Program Officer about a change of effort greater than 25% of current effort?
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 Office of Research and 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 UW Office of Research and Sponsored Programs in advance of the change.
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?
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.
When there is a reduction in effort for an individual with both cost shared and directly charged salary, to which component does the reduction apply?
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.
I am the Director of a large Center, but the PI of record is the Dean of our college. The Dean has no day-to-day involvement in the Center. Who should certify the effort for the classified staff and graduate students that work at the Center?
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.
A faculty member in our department performed more effort than what was proposed on one of his budgets. Does he need to declare this as cost sharing?
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.
What should happen when a faculty member maintains the committed level of effort but shifts how this effort is funded?
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.