SUBJECT: Effort Reporting Policy for Sponsored Agreements
Faculty Effort Certifications (FECs) are semi-annual reports designed to track the effort of faculty who have been paid from and/or have cost share commitments to sponsored project effort. A faculty member receives an FEC if he or she is paid by the University of Washington and
The purpose of the FEC is to certify that the compensation charged to sponsored agreements was a reasonable reflection of effort devoted to same. Assurance of faculty effort is required by the Office of Management and Budget (OMB), Uniform Guidance, 2 CFR 200.430, Compensation – Personal Services.
Non-faculty personnel, such as professional staff, senior fellows, and lab technicians do not receive FECs. Their effort is reported quarterly via the Grant and Contract Certification Reports (also known as Payroll Certification Report) or as otherwise agreed to by the University.
For the purposes of sponsored agreements, faculty effort is the time faculty spend on their University activities, including research, instruction, administration, service and clinical activity.
Institutional base salary is the annual compensation paid by the University of Washington for an employee's appointment, whether that individual's time is spent on research, instruction, administration, service or clinical activity. Institutional base salary excludes any income that an individual is permitted to earn outside of duties for the University of Washington.
The following chart identifies the salary sources and components considered part of the UW IBS. Harborview Medical Center (Harborview) is operated and managed by the UW. Salary support funded by Harborview is considered part of the UW IBS, and time spent at Harborview is included in the faculty work week for effort reporting. Similarly, salary support funded by UW Medical Center (UWMC) or Seattle Cancer Care Alliance (SCCA) is considered part of the UW IBS, and time spent at UWMC or SCCA is also included in the faculty work week for effort reporting.
IBS includes salary from:
IBS excludes compensation from:
* Paid direct by those organizations
A faculty work week is the average number of hours each faculty member normally works during a week. Hours are to be averaged over the effort reporting period. For many faculty this number will vary from one week to another.
As an example, if within an effort reporting period, a faculty member were to work half 60-hour weeks and half 40-hour weeks, his/her average work week would be 50 hours. Hours are averaged over six months; two calendar quarters for calendar based schools and over two academic quarters for academic based schools/colleges.
Use of the UW IBS and average faculty work week are necessary in proposing, charging, and certifying effort. The total UW IBS must be distributed across all of a faculty member's University research, instruction, administration, service and/or clinical activities. This requirement may not be avoided by characterizing true UW activities such as proposal writing, instruction, University-related administrative duties, service or clinical activities as “unfunded” or “volunteer” activity for which no UW salary is paid except when faculty are in an authorized Faculty Reduced Responsibility (RR) Status (see GIM 38).Proposal Preparation: The full uncapped IBS is to be included in the "Institutional Base Salary" and the “Requested Salary” sections of proposals. However, when a proposal is restricted by both a total award cap and a salary cap, the “Requested Salary” amount may be based on the lower of the applicable salary cap or the UW IBS at the appropriate level of effort. Charging salaries: Salaries should be charged to sponsored projects by determining the percentage of the faculty member's average work week devoted to the project and charging no more than that percentage of the faculty member’s UW IBS to the sponsored project. Charging less than the percentage worked is allowable but discouraged per GIM 21, Cost Sharing for Sponsored Agreements. When this occurs the difference between the actual effort and the amount charged must be recorded as cost sharing if it was committed to the sponsor in the proposal.
Certifying effort: Faculty certify their grant effort (both paid and committed, i.e., cost shared) as a percentage of total University effort on the faculty effort certification form.
Faculty generally have responsibilities for such activities as non-sponsored research, instruction, administration, service or clinical activity that would preclude their devoting 100% effort to sponsored activities. Proposal preparation for new and competing renewals would also preclude faculty from devoting 100% time to research (see GIM 38 for exceptions). Accordingly, faculty, department administrators, and department chairs should assure each reporting period, including summer for those on an Academic year appointment, that there are no other activities required of the faculty member that would reduce the effort available for sponsored activities during that period. Salary support for teaching, administration, service, clinical activity, institutional governance and proposal preparation effort must come from non-sponsored funds (see note below), except for normal scholarly activity during summer time outside of the main nine-month Academic year and sponsored projects specifically awarded for those purposes.
Although all University activities must be included in a faculty member's effort for reporting purposes, not all of a faculty member's professional activities must necessarily be considered University activities. For example, outside professional work and volunteer community or public service are types of activity that would normally be deemed non-University activities. Interdepartmental consulting for which supplemental compensation is paid and service on review panels or other advisory activities for federal sponsors that include an honorarium and/or travel reimbursement are also considered outside of total effort. Activities other than research, instruction, administration, service, clinical activity, and proposal writing that, in the reasonable judgment of the faculty member, in consultation with the chair (or designee) in accordance with 24-57(c) of the University Handbook, are "over and above" and separate from his or her assigned University responsibilities, may also be excluded from effort for reporting and salary allocation purposes.
Note: The policies stated above are based on the usual and customary circumstances. Unusual circumstances may arise in which special treatment of a particular activity may be warranted, but such special treatment should be approved in writing in advance by the Provost or designee.
Faculty with partial salary support: Periodically a faculty member may lose partial or full salary support due, for example, to loss of sponsor funding or other external support. If a loss of sponsor funding or other external support occurs, the faculty member will need to determine how to approach his/her total UW effort. In some instances, although receiving less than his/her base salary, a faculty member may elect to continue working at the same total level of effort as s/he was working prior to the loss of funding in which case s/he will enter into a without salary (WOS) status, distributing the time to other remaining funded activities. In other instances the faculty member may elect to reduce his/her effort to a level commensurate with the reduced salary with the intention of returning to their former level of responsibilities and corresponding institutional base salary compensation. In these cases the faculty member should apply for Faculty Reduced Responsibility (RR) status (see GIM 38). It is critical faculty work with their department administrative staff to understand, in advance, the impacts on effort and salary distributions resulting from the option chosen.
Whatever option is selected, faculty paid from or having committed effort on sponsored projects, who are partially WOS or RR, must assure the percentage of their adjusted salary (and related fringe benefits) charged to sponsored projects continues to be proportionate to the effort expended on those projects as a percentage of total UW effort. This requirement may not be avoided by characterizing true UW activities such as proposal writing, University-related administrative duties, instruction, service or clinical activities as “unfunded” or “volunteer” activity for which no UW salary is paid except when faculty are in an authorized Faculty Reduced Responsibility status (see GIM 38).
Options when a faculty member has a potential for reduced salary due to loss of external funding include:
To the extent the faculty member is unable to redistribute the salary to other funded activities or obtain bridge funding and remains in a reduced salary status, then either the action described in Option 2) or Option 3) below are necessary;
Where a faculty member's appointment is defined in terms of a time period (as in the case of nine-month faculty), total UW effort would normally include only UW activities engaged in during that time period.
OMB Uniform Guidance, Section 200.308 requires grantees to obtain the sponsoring agency's approval in writing if the PI or key personnel specifically named in the Notice of Grant Award (NGA) will:
This rule applies to all federal grants unless waived in writing by the sponsor.
The sponsoring agency must approve in advance any alternative arrangement proposed by the grantee, including any replacement of the PI or key personnel named in the NGA.
Note: The key personnel named in the NGA may differ from key personnel identified by the University in the proposal.
The effort commitment (both paid by the sponsor and paid by the University) at the time the award is issued is considered the threshold against which reductions of 25% or more need to be requested and approved in advance. In order to be in compliance, the PI should compare the original commitment in the award document against actual grant effort on the Faculty Effort Certification form.
Frequently asked questions on effort reporting can be viewed at: http://f2.washington.edu/fm/maa/faq