Federal regulations clearly acknowledge that precise determinations are not expected, and that reasonable estimates are acceptable. To quote directly from OMB UG, "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.
Performance of more effort than proposed in the budget is considered voluntary uncommitted cost sharing and is a contribution of non-sponsored effort. It is not reported as cost sharing; it is not auditable and it is not reportable.
Changes of effort greater than 25% of current effort
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 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 UMass Lowell Office of Research Administration in advance of the change.
Definition of "Administration"
“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.
Definition of "Instruction"
"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 UMass Lowell effort. It excludes continuing education activities.
NIH Grants Field: "Other Significant Contributors"
The inclusion of this field 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."
Time for Committee Activities or Service
These types of activities are considered to be administrative or instructional in nature and are part of your non-sponsored 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.
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.
Time for Grant Proposal Preparation
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.
Certification of Payroll v. Actual Effort
Certification should include actual effort, up to the sum of their paid and unpaid commitments. PIs 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.
If you have concerns about your grant application, contact the Office of Research Administration.