December 8, 2005
Some clarification on completing Faculty Effort Certifications
Although the majority of faculty who were required to complete training on Faculty Effort Certification have done so, a number of follow-up issues have arisen, according to Sue Camber, assistant vice president for research and accounting analysis.
“Faculty members, especially research faculty who are funded entirely by federal grants, are concerned that any activity, however minimal, which is not research is now prohibited. This is not true,” she says.
Faculty members who participate in shared governance activities, such as membership in the Faculty Senate or participation on faculty councils, may continue to do so, Camber says, as long as the time spent on such activities is small. “To the extent that such activities, in the aggregate, do not affect the percentage of work time allocated to sponsored research, they can continue.”
Basic activity, such as voting, or filling out an expense report, as long as it is minimal, need not be included an effort report.
Similarly, other activities, such as occasionally consulting with students, may also be permitted. Mentoring of students that is related to sponsored research is considered part of that faculty member’s research activity. Giving special lectures about research activity, writing reports and articles, participating in seminars, attending conferences and consulting with colleagues are all included in the faculty member’s research activity if “intimately related to work under the agreement,” according to Circular A-21 issued by the federal Office of Management and Budget.
The activity of writing new grant applications should be paid out of University fund sources other than grants. “This activity doesn’t directly benefit an existing grant, but it is allowable activity that may be recovered through the indirect cost process,” Camber says.
Camber emphasized that the recent effort to update faculty about recent certification issues is not based on new regulations, but it does correspond to increased federal scrutiny, and in some cases large settlements with universities found out of compliance with these regulations.
“We urge researchers who have specific concerns about the funding of certain activities to talk with departmental administrators, unit heads and deans,” she says.
The increased federal scrutiny and the large payments some institutions have made as a result of federal audits have energized the academic research community. The Association of American Universities has created a committee, chaired by the presidents of Johns Hopkins University and the University of Michigan, to examine the situation. They have been joined by representatives of the Council on Governmental Relations and the Association of American Medical Colleges. But for the time being, the reality of federal regulations and federal audits must determine how the University handles this issue.
The office of Financial Management has created a Faculty Effort Certification Web site which contains answers to frequently asked questions: http://www.washington.edu/research/maa/fec/index.html#problems. A new Grant Information Memorandum (www.washington.edu/research/osp/gim/gim35.html) on effort certification is being drafted and will be posted and distributed soon.
