The questions below are arranged by topic:
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Classification and Allocation of Effort |
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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 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 sponsored research is appropriately included in effort directly charged to a faculty member’s sponsored agreement. OMB Circular 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. |
Effort and Personal Activities |
Q. What about basic activities that are personal to a faculty member, such as voting, or completing effort reports, or expense reports? Do these activities have to be assigned to a category of effort? A: Activities such as these that are intrinsic to the faculty member's personal daily routine do not need to be separately funded and accounted for in the effort reporting system. These kinds of activities are not viewed as serving a separate university function or administrative purpose, apart from the research, teaching, clinical, or administrative function(s) in which the faculty member is otherwise engaged. It should be emphasized, however, that any effort that is associated with activity identifiable in its own right, such as proposal writing or departmental or university administration, even if it involves only the faculty member himself/herself, must be reflected in the faculty member's total effort. Moreover, should the "housekeeping" activities referred to in this guideline become more than de minimis in amount for any reason, it may be necessary to reflect them in an administrative or other category of total effort. Questions about whether activities come within this guideline may require consultation with your Departmental Administrator. Management Accounting and Analysis (Executive Director) at 6-1379 and Grant and Contract Accounting (Assistant Vice President for Research Accounting and Analysis) at 3-8951 are available to assist in this consultation as needed. |
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 that include an honorarium, per diem, and/or travel reimbursement by the federal agency need not be included in your total effort for effort reporting purposes. The University encourages such participation and does not require prior approval provided that if the activities involve time away from the University, approval for this travel should be sought from the appropriate supervisor. Such activities should be reported annually on Form UoW 1461. |
Effort and Other University Activities |
Q: How do I classify effort related to thesis committees, search committees, faculty senate committees or activities, admissions committees, and similar activities? A: Generally these types of activities are considered to be administrative or instructional in nature. To the extent such activities are de minimis in amount, meaning that in the aggregate their inclusion in or exclusion from total effort would not affect the percentages of effort allocated to sponsored research, separate tracking and funding is not required. Management Accounting and Analysis (Executive Director) at 6-1379 and Grant and Contract Accounting (Assistant Vice President for Research Accounting and Analysis) at 3-8951 are available to assist in consultation regarding such activities as needed. |
Effort and DSMBs |
Q: Since the NIH is requiring Data Safety and Monitoring Boards (DSMBs) for many studies, can participation be funded as part of a grant? A: Only if participation of a DSMB member is specifically budgeted in the grant. Otherwise effort associated with DSMBs would be part of departmental activities. |
Sample Effort Allocation Samples |
Q: Please provide some effort allocation examples. Sample Scenario 1: Faculty member Harris has 3 grants proposed at 25% (Grant A), 25% (Grant B) and 50% (Grant C). He works the first 3 weeks of a quarter on Grant A. The remainder of the quarter, he splits his time between grant B (1/3 of his time) and grant C (2/3 of his time). Over the course of the quarter, his time averages out to the percentage proposed. He may charge his grant at 25% (Grant A), 25% (Grant B) and 50% (Grant C) during the quarter as proposed. Sample Scenario 2: Faculty member Lim has 3 grants proposed at 25% (Grant A), 25% (Grant B) and 50% (Grant C). She works half of the quarter on Grant A and the reminder of the quarter, divides her time equally between grant B and Grant C. Over the course of the quarter, her time averages out to 50% for grant A, 25% for Grant B, and 25% for Grant C. For grant A, she either has voluntary uncommitted cost sharing of 25% (she only proposed 25%) which is reported under “all other activities” in the effort reporting form and/or may charge the additional 25% effort to the grant if funding is available. For Grant B, she may charge the 25% as proposed. For Grant C, her salary needs to be reduced from 50% to 25% before her effort is certified at 25% and if sponsor approval is required, she needs to seek permission for this 50% reduction in effort. Sample Scenario 3: Faculty member Findley has 2 grants proposed at 75% (Grant A) and 25% (Grant B). She spends the first 3 weeks of the quarter repairing a machine that supports both grants A and B. She spends the remainder of the quarter working 75% on Grant A and 25% on Grant B. Repair time should be allocated in accordance with the benefit received from the machine by each grant. The benefit can be based on estimates, e.g., an objective or subjective assessment of use such as hours of machine usage, total grant dollars, total grant salaries, PI Findley’s salary, etc. |
| WOS | Q:I am a member of the research faculty. For the last few years, I’ve been 100% appointed/paid with 50% of my effort and pay on grant A and 50% of my effort and pay on grant B. I’ve been working approximately 30 hours on grant A and 30 hours on grant B and receive $70,000 salary on each for a total of $140,000. Next month, grant B ends and my department is unable to bridge any of my lost salary. What are my options: Option 1: Reduce salary to $70,000. Continue to work 60 hours per week but spend all 60 hours on grant A. Your salary total of $70,000 can be paid from Grant A because 100% of your effort is on grant A. (NOTE: If funding is available from Grant A, salary may be bridged from grant A). Option 2: Reduce salary to $70,000. Reduce work hours to 30 per week and spend all of those 30 hours on grant A. Salary of $70,000 can be paid from Grant A because 100% effort is on Grant A. Q: If I reduce my time to 30 hours as in option 2, can I teach a University class or devote my time to clinical activity in my spare time? Yes, if you can obtain funding. The percentage of your effort spent on teaching or clinical activity must be funded by University sources other than sponsored projects. |
| Part time | Q: What if someone is not funded 100%? If they want to be a part time person, and have a grant that funds 50% of their full time institutional base salary (meaning it would be their total ½ time job), it seems as if the 50% on the grant means they can only devote 50% of 20 hours, instead of 100% of 20 hours. Am I misunderstanding something? A: The confusion lies with the thought they are certifying to the FTE level rather than the compensation level. The individual would be certifying to 100% of their compensation coming from the grant which represents ½ FTE. |
| De Minimus | Q: I am With Out Tenure (WOT) and work 100% time on sponsored research. I am asked to serve on an instructional board of the UW. Besides periodic 3-4 hour meetings, there will be time/effort responding to queries, emails etc. Suppose this adds up to 10 hours per year. I work on average 60 hour per week. There is no compensation for this, and I believe this is part of my general “academic responsibility” and being a good citizen. Is my participation in this activity legal? Explain why or why not. Same question, but now I am asked to serve on instructional committees for one of my joint appointment departments. One request is to run an entire course, that I estimate will take 6 months prep time at 40% effort and 50 % effort during the quarter the course runs. The dept is prepared to offer me 25% salary during the quarter I teach. How about this activity? A: The term we use to identify effort that is too low to quantify is de-minimus. This term does not specify a number of hours or percent of effort that qualifies as de-minimus. One way to evaluate your situation would be to assume an auditor from the sponsor followed you around for a month. Would that auditor have any reason to question why 100% of your effort was being paid for from their grant? If so, you should probably not have 100% of your salary paid from that grant. In the second scenario, it is evident that the percent of salary is not commensurate with the percent of effort required to accomplish the assignment. In this case additional non-grant funded salary needs to be identified to support the level of effort required.
Q: What is the de minimus time that can be charged to a grant for non-research activities without being out of compliance? For example, if a faculty does not have teaching or administrative responsibilities but attends faculty and division meetings that require less than 1% of their effort, is that de minimis? A: There is no set parameters to define what constitutes a ‘de minimis’ activity, this is situational and must be determined by the faculty member in consultation with appropriate departmental leadership. In general, an activity can be considered de minimis in amount when in the aggregate its inclusion in or exclusion from total effort would not affect the percentages of effort allocated to sponsored research. |
| 100% Research Faculty | Q: What provision is made to provide money for grant application preparation for research faculty paid 100% on federal NIH 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? What certification exists in the FEC reports for those responsible officials to assure that the funding is available and utilized? 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 indirect cost recovery, gifts, endowments, and state funds may be used to fund these activities. Department/college administration is responsible for assuring that the provisions for funding are in place. It is not a function of the FEC reporting process to monitor or certify that funding is available. The FEC reporting process is for individual faculty members to provide assurance that the compensation paid from grants and contracts is equitable to the effort expended on those agreements as a portion of the total UW activity of the individual. |
| Part time 100% grant funded | Q: Chairs I am talking with vehemently believe that faculty on soft money are on soft money, without a departmental commitment. The argument I am hearing is that for part-timers their “off” time isn’t compensated regardless of what they are doing with it. I want to do the right thing, but the result may be no longer permitting part-time faculty on soft money. A: Salary support for teaching, administration, service, clinical activity, institutional governance and proposal preparation effort must come from non-sponsored funds. |
| Emeritus 40% | Q: An emeritus faculty has been hired back at a 40% appointment (maximum allowed for retired employees) to teach. Can this individual “volunteer” time on a sponsored research project. A: Even though the faculty member is on a 40% appointment the same principals applicable to work Without Salary (WOS) are applicable. The effort attributable to the sponsored project must be considered part of the compensation of the individual. It could be implied that by approving the application for the grant that 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: Salary must be distributed to individual grants or contracts at the percentage of total University activity on those grants or contracts or at a smaller percentage. The remainder of University activity can be funded by one or many funding sources (e.g. if 20% of University activity is teaching and 20% is administration consisting of involvement in an IRB, proposal writing, and search committees, the 40% can be funded entirely by one departmental budget or by a series of departmental budgets, including but not limited to state budgets, budgets for indirect cost recovery, gifts, and endowments). 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 State and Research Cost Recovery 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 commitment? 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 considering removing everyone from grants for some portion of their time may reduce your risk, every individual’s portfolio of activities should be reviewed to determine the appropriate mix of grant and non-grant funding. The final determining factor is each individual’s actual effort. |
| 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:
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| Effort and Intellectual Property | Q: Is effort related to pursuing intellectual property (e.g. making an invention disclosure, meeting with UW’s Tech Transfer Office to discuss an invention disclosure, meeting with a patent attorney about a UW invention, 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 for it to be eligible for direct charging. 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: Some level of effort must be noted in the grant application for all key personnel. Most sponsors will accept the level of involvement of key personnel to reflect “as needed” except NIH. NIH defines key personnel as the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Therefore, an “as needed” level of effort is not acceptable for NIH grants. There is not a required minimum level, it is only required that the effort be measurable. |
| Other Significant Contributors | Q: Can a faculty 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 GIM 21: "if personnel have been asked to perform effort occasionally for an undetermined but incidental amount of time on a grant, a description such as 'participate in the design of test methodologies' or the term 'as needed' should be used in the proposal intstead of dollars and/or percentages." |
| Average Work Week | Q: I am currently a research 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: Unless specified in the letter of appointment, 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. Faculty appointments generally specify an annual salary amount that is negotiated between the department/college and the individual faculty member. This salary is not divided into the various responsibilities of the faculty member such as instruction, research and administration. The assumption is that each of these responsibilities is of equal relevant value. In other words if your time is expended in a ratio of 1/3 to each activity, 1/3 of your salary could reasonably be attributable to each of the activities. To illustrate this further, if the salary were reduced to an hourly rate, that rate would be the same for each of the areas of responsibility. Therefore 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 |
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| 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. |
| 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 like State, RCR, Gifts, Endowments, or DPA during the period when the faculty member 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: 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. If the teaching and other activities are NOT contributing and intimately 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: No. While not all non-federal grants/contracts are subject to the same rules as federal grant/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 at meeting that 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. The level of effort should be based on each faculty member’s individual situation. |
| Extended Leave | Q: What is the procedure for paying university employees assigned to work on a grant or contract when they must take extended leave (sick leave, maternity leave, family leave, vacation, etc)? What about effort reporting? What about unpaid leave? A: According to the UW policy, paid absences are charged to sponsored projects as part of the normal charge for salaries and wages. The effort report will continue to be reported based on the pre-leave salary distribution. Example: An employee’s effort/pay was 50% on a departmental budget for teaching and 50% on a research grant before taking paid leave. During the period of leave the salary would continue to be charged 50% on the departmental budget and 50% on the research grant until they return to work or through the end of the grant period. On the effort report, the pay and effort would continue to be reported at 50% departmental and 50% grant. Note: Unpaid absences are not reflected on the Faculty Effort Certification (FEC). However, extended leave may impact the level of effort committed to the project by key personnel including the Principal Investigator/Project Director. The sponsor must approve any leave that lasts for a period of 90 days or more for the PI or key personnel. In addition should a partial leave result in a reduction of time devoted to the project of 25% or more of the original commitment, sponsor approval is required. The Principal Investigator should submit to the sponsor, through OSP a request for approval to be absent from the project or reduce their time devoted to the project. |
| 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 & 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. |
| WOS New Faculty and Proposal Prep | Q: We have a new research faculty coming aboard. We are offering him a With Out Salary (WOS) appointment as we can’t fund a new Faculty who has no independent funding. It’s clear, once he has started, if he is doing grant writing we will have to fund that effort (e.g., 5%). Question – If he has written a grant and submits it prior to his faculty start date – are we required to fund 5%? A: The issue at hand is “compensated” effort. That is, if an individual is being compensated by the University and writes a grant proposal this is considered part of the individual’s University effort therefore some portion of his/her compensation would need to be charged to other than grant/contract resources. (The 5% should only be used if that it is an appropriate estimate of the effort involved.) If he/she is not being compensated, there will be no FEC generated. Writing a proposal does not require the University to pay someone who is not already being compensated. |
| 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 the IBS is clearly outlined in the FEC training and documented in GIM 35. This definition should be incorporated with all new budgets. |
| ADS/ENS | Q: What is the basis for having ADS and ENS in the base salary? A: Federal regulations define institutional base salary as “The annual compensation paid by an organization for an employee’s appointment, whether that individual’s time is spent on research, teaching, patient care, or other activities. Base salary excludes any income that an individual is permitted to earn outside of duties for the applicant/grantee organization.” Based on this regulation the institution has determined that ADS and ENS are part of the institutional base salary. |
Managing Effort |
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| 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 noted in the Notice of Grant Award) must be approved prior to the change and in writing by the sponsors’ Grants Officer. The request must be processed through the UW Office of 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. Any change in the scope of work be approved prior to the change and in writing by the sponsors’ Grants Officer. The request must be processed through the UW Office of Sponsored Programs in advance of the change. |
| Post Award Salary Changes Affecting Effort | Q: After the grant is awarded, I often find that either my salary has increased or my colleague’s salary has increased by more than the 3-4% (NIH allowed) from the time of writing the proposal to the time of award. So, for example, I propose 10% effort and my salary at the time of application is 100K therefore I have budgeted 10K. At the time of my award, my salary is 120K. If I charge the grant for 10% effort (12K), I will be in deficit from day one! In these events, can I reduce my % effort so that I match the dollar amount charged? From the website, it seems I can reduce my effort as long as it is not more than 25%. Does this situation justify it? Alternatively, I can keep my % effort but reduce the amount charged to the grant and the rest of it comes from dept funding. Which option should I use? A: The focus should be on the required level of effort to accomplish the objectives of the project/program as it was proposed. If a reduced level of effort will not impact meeting the project/program objectives then that would be the route to go. However, if the reduction is 25% or more you will need to obtain agency approval. If the proposed level of effort is required and funds are not available from the award, then non-grant funding could be used to ‘cost share’ some effort. Another option would be to approach the sponsor for additional funding or for a change in the scope of the project, if the level of funding cannot support the project due to inflation in the associated costs. To avoid or lessen the incidence of such situations it may be necessary to apply an inflation factor to the salaries used in proposals. If it is known that awards will not be issued for a significant time after proposals are submitted an inflation factor could be added to current salary levels for the first year of funding as well as each succeeding year. |
| Key Personnel | Q: “Key personnel” who require approval for 25% effort changes are those listed on the Notice of Grant Award. My PI has brought me copies of Emailed Notice of grant award and it is silent (aka not listed) as to who is key personnel. What direction should we take? Do we assume no one is key personnel? Do we assume all those listed on the Budget proposal are key personnel? A: Key personnel are defined as the PI or key personnel specifically named in the Notice of Grant Award (NGA). If the NGA is silent the PI, by default, is the only key personnel for the award. Prior approval is required if key personnel withdraw from the project entirely, will be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of award. Prior approval for a change in status pertains only to the PI and key personnel named in the NGA regardless of who may be designated as key personnel in the grant proposal. |
| Medicare Cost Report | Q: Does the faculty member need to worry about how the Medicare Cost report that s/he fills out twice a year compares to their FEC report? A: The faculty member needs to be mindful of all information s/he uses to describe his/her activities. However, since the Medicare report is a snapshot of 2 weeks every six months, it may vary from information reflected on an FEC which is averaged over a six month reporting period. |
| Faculty Evaluations | Q: What about background materials that are part of periodic faculty evaluations? Will these materials conflict with the FECs? A: Once again, the faculty member needs to be consistent when thinking about his/her time and accurately depict those times in every report s/he completes. |
| 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: From a strict policy stand point, the terms and conditions continue unless amended, so reducing effort by more than 25% would require sponsor approval. 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. |
| Direct Charged and Cost Shared Effort | Q: A PI in our department has 20% direct charged effort and 10% cost sharing on one of her federal grants. She wants to reduce her effort on the cost share to 5%. Is this OK? A: When committed effort involves cost sharing, the total amount of direct charged plus the amount of cost share equals the total effort requirement, in this case 30%. The faculty member may reduce her effort by 25% or less without requesting prior sponsor approval, but the reduction of effort should be applied proportionally to both the direct charged effort and the cost shared effort.
Q: Could this PI charge 15% effort to the grant and cost share 15%? A: Yes, The relationship between the amount of effort charged directly to the grant and the amount cost shared is secondary to the PI meeting the combined percent of effort. |
| 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: If the cost share is committed based on effort, and necessary approvals have been obtained (e.g. reduction greater than 25%), the reduction should be prorated proportionately over both the direct charged and cost shared effort. If the cost share is mandatory, specific approval from the sponsor is required unless other sources of cost sharing are substituted. |
Changes in Effort |
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| RSTs | Q: Having current and accurate information on Retroactive Salary Transfers (RSTs) is challenging. Is there a plan to improve this process? A: The Financial Desktop working group is pursuing automating the RST process. |
| Overpayments | Q: My faculty member was overpaid. What kind of documentation do I need to attach to the FEC to support the reduction in his salary reported on the FEC? A: Attach a signed Overpayment/Repayment Option form and a copy of the departmental worksheet that shows the pay periods when salary was deducted. You may also attach the HEPPS records (screen 3/35 with the dates of the cycle) if the overpayment has been documented in HEPPS. |
| UWP | Q: I have an FEC that does not reflect the UWP funding in the “Other Salary Source” section. How do I add this? A: Attach a “Change Transaction Memo” that shows the monthly UWP funding. These forms usually are on file in your department. If they are not available there, contact your dean’s office or UWP for a copy. Add the dollar amount of the clinical salary to the subtotal in the “Other Salary Source” section on the face of the FEC and recalculate the percent time to include this addition. |
| RST Documentation | Q: I did an RST which transfers salary into a budget that does not appear on the FEC. What documentation do I need to attach to the FEC? A: Attach the RST that shows that funds were transferred into this budget. You do not need any other documentation. Write in the new budget number and salary amount on the FEC. Make changes to the salary on the FEC for the preprinted budget(s) involved in the salary transfer and recalculate the percent time for these budget(s) Be sure to use the RST revised 06/02 and complete the “For Faculty Only” box. |
| Departmental Spreadsheets | Q: A faculty member’s salary changed and it does not appear on the FEC. Can I attach our department spreadsheet that shows the correct salary distribution? A: No. Departmental spreadsheets are not considered adequate documentation. Please attach an official University record of the change. Examples of these official records are screen prints from OPUS, HEPPS, RSTs, PERMS, Overpayment/Repayment Option forms, Change Transaction Memos and Xerox copies of checks. |
| Adjustments between effort and non-effort cost share | Q: I am a PI with a grant that requires a dollar match. Since supplies for this project were significantly more than anticipated, I would like to use these charges to satisfy the cost sharing instead of my originally proposed effort. Is this OK? A: Yes, with the following caveat, regardless of whether the cost sharing is percent effort or total dollars, if there is a specific commitment of effort by the PI or other key personnel, and the re-budgeting is caused by or results in a significant reduction (i.e., 25% or more) of that commitment, prior approval from the sponsor for this change needs to be obtained. Additionally, significant adjustments between effort and non-effort categories may imply a scope change. If this is the case, then the sponsor must be contacted to approve the change. |
| Fluctuations in Level of Effort | Q. Can a PI reduce his/her effort during an FEC cycle by more than 25% if the total effort during the budget period is compliant with the commitment on the grant? Does the PI still have to contact the sponsor for prior approval? A: Effort should be met over the budget period, not necessarily over the FEC cycle. Effort may vary from FEC cycle to FEC cycle as long as the PI(s) or key personnel as designated in the NGA do not
Unless one or more of the three issues noted above apply, there is no need to request prior approval from the sponsor for fluctuations in effort. |
Nine Month Appointments and Summer Salary |
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| Cost Sharing during Summer | Q: I have a faculty member who has a 9 month appointment and is working on her NIH award in the summer. She does not have departmental support during the summer and therefore cannot meet the salary cap cost sharing required. Can she do the cost share in another quarter? A: No. Salary cap cost sharing must be provided during the period in which the effort is performed. Therefore, it is advised that the department plan accordingly and identify non-grant funding to cover the cost sharing required by the salary cap in the summer. |
| 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 FEC process is generally conducted on a quarterly schedule for faculty on 9 month appointments. Summer effort is accounted for on the summer quarter FEC (June 16 – Sept 15th). The rate of pay one can receive from a grant for work during the summer is based on their 9 month academic year salary rate. While summer salary is considered part of institutional base salary, it is generally a unique line/designation in the grant proposal. For example, if 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. This will currently show up on the FEC as 33% because the FEC is averaging over a three month period. |
| Administrative Supplements | Q: A faculty member has a nine month, 100% state paid salary and during that time draws an endowed supplement (ENS). The state paid salary is $10,000 a month and the ENS is an additional $1,000 a month. Thus, IBS during these 9 months is $11,000. During the summer, this faculty member intends to devote 100% of one summer month effort to his/her grant. Does inclusion of ENS in IBS mean the grant can be billed $11,000 a month, total of state salary and ENS? A: Yes, the endowed supplement is part of the IBS and would be included in calculating the grant proposal budget. Therefore, the salary paid over the summer would be based on the $11,000 monthly salary rate for the faculty. This is consistent with OMB Circular A-21, J. 10d, 2, which states: “charges for work performed by faculty members on sponsored agreements during the summer months or other period not included in the base salary period will be determined for each faculty member at a rate not in excess of the base salary divided by the period to which the base salary relates. The base salary period used in computing charges for work performed during the summer months will be the number of months covered by the faculty member’s official academic year appointment.” The NIH definition of IBS makes it clear that NIH considers ALL compensation paid to an employee for ALL activities of the employee on behalf of the employing institution, as IBS. For this reason it has been determined that supplements, other than short term supplements, are a part of IBS. Q: In the example above, if the extra $1,000 during the 9 month is an administrative supplement and the faculty member will do NO administration during the summer, can the grant be charged $11,000 for 100% effort on the grant (all of it research, none of it administration. A: Yes, same answer as above |
| NSF Academic Year Support | Q: Does NSF pay academic year support? A: Compensation for doing research is often included as part of a faculty member's regular salary and in those cases, academic year salary would not be appropriate. If, however, a faculty member has a teaching appointment, it may be appropriate to request academic year support. The caveat is that some NSF Divisions/Directorates have more restrictive policies with regard to academic year support than others. Therefore, the best thing to do is to check with the cognizant Program Officer to discuss the issue. |
Totals |
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| Changing Totals | Q: I changed the total % on FEC line “Total Average Paid Salary.” Is there anything else I need to do? A: The top half of the FEC presents salary information while the bottom half is where the faculty member confirms their effort. Since the payroll should be a reasonable reflection of the effort performed, these two totals should match. The total % on FEC line “Total Average Paid Salary,” therefore, must be the same as the total on FEC line “Total of All Activities.” Check to see that you have changed both totals. Also check that one or more of the budgets on FEC lines “Grants and Contract” and/or “Other Salary Sources” have been changed to reflect the new % total. If the change is due to changes in salary amounts, attach appropriate documentation. If the change is due to rounding, you do not need to attach documentation. |
Whiteout |
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| Whiteout and Tape | Q: I made a mistake on the FEC for a faculty member in my department. Can I use whiteout to correct it? A: No. Whiteout and white tape are a concern for auditors as corrections can be made to the form after the faculty member, chair or dean has signed it. Cross out the incorrect amount and write the correct amount at the side. If whiteout is accidentally used, the faculty member needs to initial the change. |
Signatures and Initials |
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| Who Can Sign the FEC | Q: The faculty member is out of the country. Can my administrator sign the FEC? A: No. The administrator may not sign the FEC. Only the faculty member whose name is on the form or the department chair or dean may sign the form. Always send an informational copy of the FEC to the faculty member if the chair or dean signs the FEC. |
| Xeroxes | Q: A faculty member in my department has lost his FEC. Can I send you the Xerox I made for the department files? A: Xeroxed signatures do not meet the auditor’s requirements. You can use the Xeroxed form, but have the faculty member re-sign the form in ink. |
Cost Sharing |
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| Using a non-federal grant as a source for cost sharing | Q: We are allowed to use one of the grant budgets listed on FEC line “Grants and Contracts” as a cost share source. How do I report this on the FEC? A: Some non-Federal grant budgets do allow their funds to be used as a source for cost sharing. In these cases, complete the following:
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| Salary Cap and Committed Cost Sharing | Q: I have a faculty member who has a 10% committed cost share pledge and 0.7% salary cap cost share requirement. Can the salary cap cost share be included as part of the committed cost share? A: No. Salary cap cost sharing is part of the original effort commitment. For example, if a faculty member committed 10% effort in his/her proposal but was over the cap, the sponsor would pay 10% of the cap and a non-federal, non-grant funding source would pay 10% of the difference between the cap and the faculty member’s total salary. This satisfies the original effort commitment. (Example of Methodology for Proposing Salary on an NIH Proposal When Salary Exceeds the NIH Salary Cap) Cost sharing is additional effort over and above the original effort commitment. For instance, if the faculty in the example above was to offer 5% cost sharing, that would be in addition to the original 10% commitment. . The faculty member would then owe 15% total effort on the grant. In the example above, the faculty member may have
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| Salary Cap and K Award Cost Sharing | Q: What about K award cost sharing? Can the cap cost sharing be used to satisfy the 75% effort requirement? A: Cap cost sharing, while it may not be used to satisfy mandatory or committed cost sharing that is based on effort, it does contribute toward fulfilling the original effort commitment. Cap cost share, therefore, can be used as part of the cost share necessary to document the required 75% effort required by the K Award.. Example: Dr. Einstein’s institutional base salary is $200,000 and the current cap is $186,600.
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| Cost Share Totals | Q: Where can I check actual cost share figures? A: Look at the budget driver to see the pledged and actual cost sharing on your budgets. In Administrative Applications open BGT, choose option 6 (Faculty Effort Certification), then choose option 3 (Cost Share Inquiry Screen). You can view the information in one of two ways:
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| Cost Share Codes | Q: What do the letters M, R, A and C stand for on the cost share inquiry screen. A: Cost share on this screen is coded M (Mandatory), R (Committed), A (Aggregate) and C (Salary Cap). K award cost sharing will also be recorded as R, but without a pledge. |
| 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” (formerly called “other voluntary cost sharing”) and is captured on FEC line “All Other Activities.” |
| Cost Share Inquiry Screen | Q: How can I tell if we have met the cost share requirements on a particular budget? A: At the bottom of the inquiry screen there is a column showing the total pledged dollar and percent amounts and another showing the total actual cost share dollars and percents. For cost share committed in dollars, if the actual dollars equal the pledged dollars, cost share requirements are met. These figures include salary, benefits and related Facilities and Administrative (indirect) costs. For cost share committed in percent effort, the pledged percent must equal the actual percent. |
| eGC1 and Cost Sharing | Q: The addendum to the eGC1 provides data to the budget driver, which is documented on the FEC as cost share. This information is not updated and is not always correct. How does this meet the compliance requirements? A: UW will be working on how to improve the addendum to provide the accurate information for GCA to enter into the budget driver. In the meantime, if the amount of the award is reduced, the department should work with OSP to determine if the sponsor should be contacted to reduce the amount of cost sharing accordingly. Once this is done, and confirmation is received from the sponsor OSP will issue a revised NEA that GCA will use to adjust the cost share. (The department needs to provide a new GC1 Addendum. This is still not part of eGC1.) The budget driver, and therefore the FEC, will then reflect the corrected amounts. If the department chooses not to contact the sponsor to reduce effort, the faculty member is obligated for the effort committed in the proposal even if the award was reduced. Departments should always review the cost sharing set up in the budget driver at the beginning of the grant to ensure it is what the department expects to see. |
| Carryover of Cost Sharing Deficit | Q: If a department has multiple faculty performing cost sharing on a grant that lasts three years and during year one does not meet the cost sharing, can the department carry over the deficit into year two? Do they need prior permission? A: Unless specifically stated in the award or by sponsor policy it’s generally not a requirement that cost sharing be met evenly throughout a project (i.e., year to year) although sometimes there are those expectations. |
| 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 share commitment. For example, a faculty 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 share situation which should be documented on the FEC.
Q: If a shift in effort funding creates a cost share commitment does a GC-1 addendum need to be submitted? A: If the cost share commitment is for longer than three months, a GC-1 addendum, with administration approval, must be submitted to GCA. Note that the GC-1 Addendum need not be submitted to OSP. For cost sharing of three months or less, no GC-1 Addendum is required. The cost share should be noted on the FEC report along with a comment noting the faculty member’s level of committed effort. |
Salary Caps and Limitations |
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| Salary Supplementation for K Awards | Q: What are the rules regarding salary supplementation for K Awards? A: Salary supplementation refers to any additional funds the institution must contribute to make up any difference between the K awarded salary limitations and actual salary for the K-covered effort. For example, the required 75% effort for a faculty member with a $125K IBS would be $93,750.
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| K Awards and Federal Support | Q: Can Federal support be used for salary above the K effort? A: The question of whether or not Federal support can be used for salary above the K award effort may actually depend on the particular K award. Some K awards actually require other NIH support. Others imply that since the K award experience is considered full-time there is no room for Federal funded activities outside of the K award activities. However, in most cases if only 75% effort is devoted to the K award, then the remaining 25% can be devoted to other projects as long as they are K related and contribute to the K award experience. |
| K Awards and Proposal Writing | Q: A Faculty member has a K award which covers 100% of her effort. Stipulated in the grant, she is expected to write new grants to foundations and the Federal government. Is it allowable for her to carry out that work as part of her 100% effort on the K award? The grant writing would be related to the line of research she is following but she would be writing for new money to support this research after the K award ends. A: While the "K" award mechanisms have some unique terms and conditions, they are still subject to the NIH Grants Policy Statement (GPS). Under allowable costs the GPS says that proposal costs are to be treated as F&A. The "K" award terms and conditions do not circumvent this treatment of proposal costs. The department needs to support the proposal preparation time from non-sponsored funds. |
| K Award Rebudgeting | Q: A faculty member has 95% effort on a K Award. Can they decrease their effort on the K award to 75% and use the remaining 20% effort paid by the K to work on other projects that are "consistent with the objectives of the award"? A: No. It is not allowable to charge payroll to a 'K' award for effort directed towards another project even if they are closely related. Q: In a K Award, can some of the research direct costs be re-budgeted to salary? For example, most K-23 awards include $75,000 annual salary + $25,000 annual research costs. Can one re-budget to, say, $85,000 annual salary + $15,000 annual research costs? A: The NIH does allow institutions, under Expanded Authorities, to re-budget within the total costs awarded to cover salaries provided the salary is consistent with the institution's salary scale. Care must be taken however as salary limits for NIH career awards are not consistent. Therefore, it is suggested one contact the NIH component to determine if a maximum contribution to the candidate's salary exists. Also, it is very important to acknowledge that the salary may not exceed the NIH salary cap. To illustrate, an individual with an annual (12 month) salary of $200,000 originally budgets 75% effort to a "Mentored Patient-Oriented Research Career Development (K23) Award". K23 awards provide for salary support from $75,000 to $186,600, the present NIH salary cap. Because of the salary cap the original salary awarded was $139,950 ($186,600 x 75%). If the recipient is actually contributing 85% effort then it is permissible to re-budget to accommodate the additional $18,660 in salary resulting from the increased effort (85% x $186,600 less $139,950 already awarded) provided the funds are available within the original budget award. |
| Salary Cap Increases | Q: Can the NIH salary cap increase during the life of a grant? A: Yes. If the NIH increases the cap, you can increase the salary line for a faculty member up to the new salary cap level if there are sufficient funds in the budget and the change is within the allowable re-budgeting parameters. |
| Salary Cap and Contingent Salaries | Q: Does the salary cap apply to faculty with contingent salary? A: In most situations, the contingent salary represents 100% UW compensation for 100% UW effort on an appointment that is not specified at less than full time. If the MOU or appointment letter specifies less than a full time appointment and the full time equivalent salary is greater than the salary cap, then the salary cap should be applied. For example, if the salary cap is $185,000 and a faculty member is receiving $150,000 for 100% effort, then he/she is not over the cap. However, if the MOU or appointment letter specifies 75% FTE, then the full time equivalent salary is $200,000 and the cap needs to be applied. |
| VA and PDR | Q: I understand the new definition of IBS does not include paid direct dollars, including VA, and that these dollars should not be considered when determining whether a faculty member exceeds the salary cap. What is the start date for this policy? A: This policy was adopted in the spring of 2005. The start date was set at 12/16/04 to coincide with the start of the start of the winter quarter. |
| K Awards for VA/UW faculty | Q: The K-award section of the FEC training states that the VA appointment should be 2/8ths. I have a faculty member who has a 5/8ths appointment; can s/he still apply for a K award? A: Generally, we would like the faculty member to have no more than 2/8ths appointment at the VA if s/he is going to apply for a K-award. However if, after discussing with his/her Department Chair, it makes sense for the person to apply and s/he has 2/8ths but not more than 5/8ths VA appointment, approval may be requested by sending a letter to the SOM Dean’s office, Office of Finance and Administration/Departmental Support (Julie Reid). |
| K Awards and proposal preparation | Q: Can I charge time spent on proposal preparation for a research grant to my K-award? A: NIH, in consultation with the Office of Management and Budget (OMB), has confirmed that limited charging of bid and proposal preparation, as a direct charge to the K-award, is allowable since it is the goal of these awards to train young investigators in all phases of research including preparing proposals. |
Copies |
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| FEC replacements | Q: Help. My PI lost her FEC. Can I get another? A: Ask the Office of Management Accounting and Analysis at 206-685-7395 to send you a new one. |
| Blank FECs | Q: I need to complete a blank FEC for a faculty member who did not have a FEC printed for him. Where can I get one? A: Call MAA at 206-685-7395 and ask them to send you a blank FEC. |
| Blank Salary Cap Addenda | Q: I did an RST that transferred expenditures into an NIH budget. Since the PI is over the salary cap, I need to prepare a salary cap addendum. Where can I get a copy? A: Download and print this blank salary cap addendum. |
Rounding |
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| Rounding | Q: The total percent time on FEC line 4 of my faculty member’s FEC is 99.8%. Since she is a fulltime employee, do I need to change this to 100? A: You do not need to adjust total effort between 99% and 100%. Q: My PI insists that the rounding be corrected on the FEC. Can I change these figures? A: Yes. Round the incorrect percent times for each budget involved and check to see that both FEC lines 4 and 8 reflect the corrected totals. |
Prorated Salary |
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| Prorated salary on FECs | Q: A faculty member in my department worked fulltime for two months in the summer, but his FEC only shows 66% effort. Could this be right? A: Yes. All salary and percent time is prorated over the entire quarter (three months) on the FEC. |
Clinical Salary |
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| Adding clinical salary to FEC | Q: UWP was missing from my faculty member's FEC. I have attached a Change Transaction Memo. Is there anything else I need to do? A: Yes. Recalculate the total dollars on the “Total Average Paid Salary” line and the percent time for each budget listed including the new total dollar amount. |
Revisions |
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| Revising an FEC | Q: We had to do an RST for a faculty member in our department. He already submitted the FEC. What do we need to do? A:
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Training |
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| FEC Training | Q: How will FEC education be continued in our system? A:
Q: How will FEC training be monitored now and over time? A: Through the same automated process the Faculty Grants Management Training uses. |
