| Questions and answers are arranged by topic:
|
Effort Policy
| New Guidelines |
Q: Why are we updating our effort policy and practices?
A: Our current PAR system was built 30 years ago, and it met the federal
standards of the day. However, as the federal government has revised its regulations,
the PAR system has not been readily adaptable to change. The University recognizes
its responsibilities for stewardship of sponsored funds and has made the investment
in new policies, guidelines, and an electronic system. In addition, the number
of effort statements generated by PAR has grown to almost 20,000 a year. The management
of 20,000 paper PARs circulating across campus is a serious challenge for faculty
as well as staff in departmental and dean's offices. |
| Who must certify |
Q: I work on a non-federally funded project and have not needed to certify my effort in the past.
Will I now need to do so?
A: Anyone who works on a federal or non-federal sponsored project must certify their effort or have it
certified by the PI or PI Designee. This includes faculty, academic staff, classified staff, graduate students,
and postdoctoral trainees. The University applies the same standards for fiscal accountability to both federal
and non-federal sponsored projects.
Q: I am an emeritus faculty member and am contributing my time to my sponsored research project.
Will I still need to certify, even though I am not receiving salary support?
A: 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
ECRT system is initially loaded from payroll, you may need to use a manual process for certifying. |
| Certifying effort |
Q:I am a classified worker on a sponsored project. Will I need to certify?
A: Unless you are the PI, you will not need to do your own certification. The PI, or someone
else with suitable means of verification, will certify for you.
Q: What does the effort coordinator do? Does she certify the effort, too?
A: The Effort Coordinator is a key resource to the faculty and the department in the effort reporting process.
Effort certification in ECRT is a two-step process: 1) the faculty or staff member certifies the statement,
and 2) it must then be reviewed and processed by an Effort Coordinator. Until the Effort Coordinator has
reviewed the certification and submitted it to RSP, the certification is not complete.
Q: I hold joint appointments in two different colleges. Each is a half-time appointment.
Who is my effort coordinator?
A: For each individual in the ECRT system, a primary department has been assigned.
The effort coordinator in your primary department will process your statement. It
is possible that s/he will need to confer with the effort coordinator in your secondary department
should any cost transfers, etc., be required. |
| IBS |
Q: What is IBS?
A: Institutional base salary (IBS) is the annual compensation paid by the University of Wisconsin-Madison
for an employee's appointment, whether that individual's time is spent on research, instruction, administration,
or service. Institutional base salary excludes any income that an individual is permitted to earn outside of
duties for UW-Madison. It also excludes any compensation paid by the UW Medical Foundation. It may include
salary paid from State funds, Grants or Contracts, Gifts and Endowments, and/or other UW funds. |
| Sponsored activity |
Q: What types of activities can I charge to my grant?
A: 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
- Providing research patient care
- 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
Q: What activities cannot be allocated to my sponsored project?
A: 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
- Clinical activity, except patient care for an IRB-approved sponsored research activity
- 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 UW 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
|
Classification and Allocation of Effort
| Effort and Payroll |
Q: I am a new administrator, and am unclear about whether we want our researchers to
certify their payroll or their actual effort?
A: 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 and Instruction |
Q: For purposes of effort reporting, what does "instruction" mean?
A: "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 UW effort. |
| Mentoring and Sponsored Research |
Q: What about mentoring of students that relates to a faculty member's sponsored research?
A: 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. |
| Effort and Administration |
Q: For purposes of effort reporting, what does "administration" include?
A: 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. |
| Effort and Review Panels |
Q: Is effort that is related to service on review panels or other advisory activities
for federal sponsors included within my total University effort?
A: 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. |
| Effort and Other University Activities |
Q: How do I classify effort related to thesis committees, search committees, faculty
senate committees or activities, compliance committees, and similar activities?
A: 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.
|
| De Minimis Effort |
Q: I am an academic staff member and work 100% on a sponsored research grant. I am also
on the UW's Committee on Women, an activity that I spend a few hours a year on. Is that ok?
A: 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 UW 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 UW 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. |
| 100% Research Appointments |
Q: What provision is made to provide money for grant application preparation for research
faculty paid 100% on federal grants? What is the source of the funds and who is responsible for providing those
funds for grant application preparation? What provision does the UW make for service on the Faculty Senate by
100% federally funded research faculty? What provision does the UW make for service on the Human Subjects IRB
by 100% federally funded research faculty? Who is responsible for assuring that those provisions for funding
are in place?
A: 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 101 (GPR) 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. |
| Emeritus 40% |
Q: An emeritus faculty member has been hired back at a 40% appointment to teach.
Can this individual "volunteer" time on a sponsored research project?
A: Even though the faculty member is on a 40% appointment, the effort devoted to the sponsored
project must be considered part of the individual's total UW effort. It could be implied that, by approving
the application for the grant, the department officials have approved a change in the scope of the appointment
to include research. |
| Funding Sources |
Q: Do I need a separate funding source for each teaching, administrative, clinical or
service activity in which I participate?
A: No. Only your individual sponsored projects must be segregated by funding source. It is important
to remember that the salary distribution must match or be lower than the effort you are committing to the project.
Under no circumstance should you ever charge salary to a sponsored project that represents more effort than you
are devoting to the project.
Q: What non-grant funds can be used to support the activities that can't be charged directly to grants?
A: Virtually any University budget that doesn't have other restrictions placed on it by the funding source,
including 101 (GPR) funds. Gifts and endowments are appropriate sources if the activities are consistent with donor intent. |
| % of Non-Federal Sources Required for University Activities |
Q: If we set a college or departmental policy and pay everyone a set percentage (e.g. 5%)
from non-grant funds, have we met our obligation to cover non-sponsored effort with non-sponsored funds?
A: While the percentage you set may be the right funding mix for some, others may work significantly
more or less on research. So, while this approach seems like a simple solution, it does not meet the federal standards.
Each individual's portfolio of activities should be reviewed to determine the appropriate mix
of grant and non-grant funding for the individual. |
| Risk Areas |
Q: What risk areas should we focus on as a school, college, or department?
A: 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?
|
| Effort and Intellectual Property |
Q: Is effort related to pursuing intellectual property (e.g. making an invention disclosure,
meeting with WARF to discuss an invention disclosure, reviewing internal action on a patent application and/or
reviewing a draft patent application) on UW awards included within my total University effort and can it be
directly charged to grants?
A: 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. |
| Minimum Effort for Key Personnel |
Q: Is there a minimum level of effort required for key personnel in grant applications?
A: In keeping with federal policy, it is the UW's policy that all PIs must have some minimal commitment
to the sponsored project. 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. |
| NIH Other Significant Contributors |
Q: Can a faculty member be noted as contributing to a grant without committing effort?
A: 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." |
| Average Work Week |
Q: I am currently a faculty member at UW. 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. |
Charging Salary
| Funding Grant Proposals |
Q: How is my effort preparing my next grant proposal funded?
A: 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.
|
| Funding Grant Proposals for 100% Research Faculty |
Q: 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: A portion of salary consistent with the effort needed for preparing the proposal should be paid from
non-federally funded sources, including 101 (GPR), gifts, endowments, etc. during the period when the researcher
is writing the proposal The percent should be consistent with % effort spent on proposal preparation.
|
| 100% Research and Other Activities |
Q: What if that same person teaches or is involved in other scholarly activities and is
100% funded for research. Is that okay?
A: 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. |
| Appropriate Source of funding for Grant Writing |
Q: Can a faculty member use a non-federal sponsored funding source (i.e. pharmaceutical
dollars) to cover their grant writing effort?
A: 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. |
| Minimum % Required for Proposal Prep |
Q: Is there a "policy" or "point of clarification" on the minimum appropriate % of effort
needed for grant writing? I recall a meeting at which 2.5% and 5% were thrown around as possible minimums.
A: There is no guideline or directive from the UW (or the federal government) on the minimum appropriate
effort for grant writing since it varies broadly by faculty member and by the specific proposal. The level of effort
should be based on each faculty member's individual situation and the time that is devoted to any particular proposal. |
| Vacation |
Q: What about vacation time when there are multiple grants? How does one insure that each
grant pays their fair share of vacation time?
A: 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. |
| IBS |
Q: We are in the middle of a 5 year award. When we submit our budget for next year, should
we use the new definition of IBS?
A: Yes. The current definition of IBS is clearly outlined in the effort training and documented in the
Guidelines for Effort Reporting. This definition should be incorporated with all new budgets. |
Managing Effort
| Reduction or Increase in Effort |
Q: 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?
A: 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 UW Office of Research and Sponsored Programs 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. |
| No Cost Extensions and Effort |
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. |
| Reduction of Cost Shared Effort |
Q: 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?
A: 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. |
Changes in Effort
| Cost Transfers |
Q: Having current and accurate information on retroactive cost transfers is challenging.
Is there a plan to improve this process?
A: There are plans under development for a web-based system for routing and approving costs transfers on
sponsored projects. |
Nine Month Appointments and Summer Salary
| Summer Salary |
Q: I am still not clear as to how summer salary or other salary relates to your effort during
the academic year and how to report this.
A: The effort certification process is conducted on a semi-annual schedule for all faculty, including those on
9-month appointments. The certification periods are from January - June and July - December. 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. |
PI Designees
| Delegating authority |
Q: I will be out of the country doing research during the effort certification period, and
will not have access to the internet. Can my administrator certify my effort statement?
A: Only a person with a suitable means of verifying how you spent your time can certify your statement in your
absence. All requests for delegating certification authority are reviewed by the Associate Vice Chancellor for
Research Administration and approved on a case-by-case basis.
To request a delegation of authority:
The RSP Effort Administrator will notify both you and the Designee when the change has been made via email. |
| Centers |
Q: 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?
A: 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. |
Cost Sharing
| Voluntary Uncommitted Cost Sharing |
Q: 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?
A: 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. |
| Shifts in Funding Source |
Q: What should happen when a faculty member maintains the committed level of effort but shifts
how this effort is funded?
A: 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. |
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