Module 9. Managing effort while working on your projects
The emphasis thus far has been on preparing you to certify effort.
Now we want to highlight some additional important issues. In this
module we explore the interplay between your effort commitment, your
actual effort, and your salary charges during your work on a project. Six key principles are:
| 1. | |
You are required to fulfill your effort commitment
for each sponsored project budget period. |
| 2. | |
During a sponsored project budget period, your actual level of
effort may vary. |
| 3. | |
Except for short term fluctuations, your salary charges
must be consistent with your actual effort. |
| 4. | |
If you wish to change your commitment, you must
always document the change and in some circumstances you must obtain prior written
approval from the sponsor. |
| 5. | |
If you maintain your commitment level and
your actual effort but reduce your salary charges to the grant, you must document
this increase in your cost-shared effort. |
| 6. | |
If you receive an award from the sponsor and the budget is significantly
less than you proposed, you must decide how you will conduct the project and
then confirm this with the sponsor – because the sponsor does not assume
a proportional reduction of effort commitments. |
This information is intended primarily for PIs, but the principles are important for all certifiers.
Effort variations within a sponsored project budget period
During the course of a sponsored project budget period, your level of effort
may vary. This is acceptable, as long as you fulfill the overall commitment for
the entire budget period.
Example
If you have committed 30% of your effort to a
project during a calendar year budget period, one way you could fulfill that
commitment is by expending:
| • | |
40% effort during the first six months of the year, and |
| • | |
20% during the last six months. |
When does a variation in effort require an adjustment to the salary charges?
You must charge salary and certify your effort in a
manner that is consistent with how you actually devote effort to the project. In
the example above, where you work 40% in the first six months and 20% in the
last six months – a perfectly acceptable way to fulfill the commitment –
it would not be acceptable to:
| • | |
Charge salary at a constant 30% rate for the
entire budget period, or |
| • | |
Certify effort at a constant 30% rate for both of your six-month periods of performance. |
However, short-term fluctuations of two months or less are acceptable.
This would be an effort deficit of not more than two months, provided that the
catch-up occurs within a comparable period and it all evens out.
When does a change in effort require prior approval from the sponsor?
The rules depend on the type of change and your role
on the project. First, the federal government defines a significant change
in work activity as:
| • | |
A 25 percent (or greater) reduction in the level
of committed effort |
| • | |
An absence from the project of three months or more |
| • | |
A withdrawal from the project |
For a principal investigator/project director or key person
as listed in the Notice of Grant Award (NOGA):
| • | |
A significant change in work activity requires prior
approval in writing from the sponsor's Grants Officer. It is not okay to just
communicate the change to your Program Officer. |
| • | |
Any other change in your level of committed effort must be documented and
communicated to the sponsor. |
Example
Your committed effort is 40%, and you want to reduce it to 30%. The drop is 25 percent
of your original effort commitment, so it requires prior written approval from the sponsor.
For a key person as identified in the proposal who
is not listed in the NOGA:
| • | |
Any change in your level of committed effort must be documented. |
For individuals who are not key personnel, commitments are not recognized
and changes to effort levels need not be documented or communicated to the
sponsor.
Changing the salary charged to a sponsored project
PIs generally have some flexibility in managing their
sponsored project budgets, including their salary charges for project staff.
However, this rebudgeting authority does not confer the right to:
| • | |
Make significant changes in work activity without
prior approval from the sponsor, or |
| • | |
Change effort commitments for key personnel without documenting the changes. |
Furthermore, if you reduce a person's salary charges without changing the effort
commitment, that's an increase in cost sharing and should be documented as such.
Taken together, the rules regarding changes to salary charges and commitment
levels are somewhat complex. They're summarized below, but you don't
need to memorize them; the specifics
are always available on the RSP Web site. For a significant change in work
activity, documenting the change means communicating it to RSP after
getting the sponsor's approval. For all other changes,
documenting means maintaining a written or emailed record at the department level.
For an investigator or key person:
| If you want to: |
|
Then you must: |
| Reduce the salary charges without changing the effort commitment |
|
Document as cost sharing the effort for which the sponsor
will not provide salary support |
| Reduce both the salary charges and the effort commitment by less
than 25% of the original commitment level |
|
Document the change to the commitment level |
| Reduce both the salary charges and the effort commitment for a key person as
listed in the NOGA by 25% or more of the original commitment level |
|
Obtain approval from the sponsor prior to the change and in writing, and
document the change to the commitment level when approved |
| Reduce both the salary charges and the effort commitment for a key person listed in the
proposal but not in the NOGA by 25% or more of the original commitment level |
|
Document the change to the commitment level |
For a project staff member who is not an investigator or key person:
| If you want to: |
|
Then you must: |
| Reduce the salary charges without changing the effort |
|
Document as cost sharing the effort for which the sponsor
will not provide salary support |
| Reduce the salary charges and the effort by commensurate amounts |
|
No documentation, notification, or approval is required |
When the awarded budget is less than proposed
If you receive an award from a sponsor and the budget is less than you proposed,
you cannot assume that your effort commitments are automatically reduced by a
proportionate amount. You may need to confirm the effort commitments and the
arrangements for salary support with the sponsor.
You have three options:
| 1. | |
Reduce the effort commitments in proportion
to the budget reduction. With a budget reduction of 25% or more, you must request
approval from the sponsor for this option. A reduction of that magnitude (10% or
greater on an NSF award) generally indicates a project scope reduction, so a
proportionate reduction of effort commitments would be appropriate. |
| 2. | |
Keep the proposed effort commitment and salary arrangements,
and reduce expenditures in non-salary budget categories. |
| 3. | |
Keep the proposed effort commitments but reduce the salary charges. This
increases the university's voluntary cost sharing for the project, and must
be explicitly approved in accordance with your college or school's policies on cost sharing. |
No-cost extensions
The terms and conditions of your award apply throughout the project period,
including a no-cost extension period. This includes the PI's effort commitment.
At the same time, federal agencies realize that PI effort may be reduced during
no-cost extensions as the project is winding down, or when data analysis requires additional time.
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.
|