GIM 35
Effort Reporting Policy for Sponsored Agreements

UNIVERSITY OF WASHINGTON

GRANTS INFORMATION MEMORANDUM 35

December 1, 2005

SUBJECT: Effort Reporting Policy for Sponsored Agreements

RELATED INFORMATION: GIM 1 (proposal development)

Effort Certification

Faculty Effort Certifications (FECs) are quarterly or semi-annual reports designed to track the effort of faculty who have been paid from and/or committed to sponsored project effort. A faculty member receives an FEC if he or she is paid by the University of Washington and

• Performs effort paid on federal and/or non-federal sponsored projects;
• And/or performs cost sharing on federal and/or non-federal sponsored projects.

The purpose of the FEC is to certify that the pay was a reasonable reflection of effort. Certification of faculty effort is required by the Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions.

Non-faculty personnel, such as professional staff, senior fellows, and lab technicians do not receive FECs. Their effort is reported on monthly Grant and Contract Certification Reports (also known as Payroll Certification Reports) or as otherwise agreed to by the University.

What is Faculty Effort?

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.

What is Institutional Base Salary (IBS)?

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.

This c hart 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 included in the faculty work week for effort reporting.

* Paid direct by those organizations

Faculty Work Week

A faculty work week is the average number of hours a 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 13 weeks for quarterly effort reporting and six months (two calendar quarters) for semi-annual reporting.

Distribution of effort

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.

Proposal Preparation:The full uncapped IBS is to be included in the "Institutional Base Salary" section of proposals. The “Requested Salary” is 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) and is recorded as cost sharing if it was committed to the sponsor in the proposal.

Certifying effort:On the faculty effort certification form, faculty certify to their grant effort (both paid and committed) as a percentage of total University effort.

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. Accordingly, faculty, department administrators, and department chairs should assure each reporting period, including summer for those on a quarterly reporting period, 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 partially without salary (WOS): From time to time a faculty member may become partially or fully without salary (“WOS”) due, for example, to loss of sponsor funding. If a loss of sponsor funding 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 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. It is critical that 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 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.

Options when a faculty member has a potential for WOS include :

• Continue to contribute the same level of effort on grants, but move effort and salary to other funded projects or obtain bridge funding. For example, a faculty member who was working 60% on Grant A ($60,000 salary) and 40% on Grant B ($40,000 salary), might switch to 100% effort to Grant A when Grant B ends. Funding 100% of their salary ($100,000) from Grant A might be possible. Funding an additional 20% from Grant A (for $80,000 total) and 20% ($20,000) from departmental bridge funds, for example, might also be possible.

To the extent the faculty member is unable to redistribute the salary to other funded projects or obtain bridge funding and remains partially WOS, then either the action described in Option 2) or Option 3) below are necessary;

• Faculty member is placed in a WOS status for a portion of his/her salary but continues to spend the same amount of total time on university activities, devoting the entire time to remaining funded activities and, when necessary, redistributes salary to reflect effort. For example, a faculty member who was working 60% on Grant A ($60,000 salary) and 40% on Grant B ($40,000 salary), might spend the same total amount of time on grants, but spend it all on Grant A. Grant A, in this example, is unable to fund any of the faculty member’s salary, so the faculty member is paid $60,000 from Grant A and is $40,000 WOS. This is an appropriate charge to the grant because 100% of remaining activity is on Grant A and 100% of the remaining pay is on Grant A; or
• Faculty member is placed in a WOS status for a portion of his/her salary and faculty member reduces his or her total time on university activities commensurate with the reduced funding so there is no uncompensated effort and, when necessary, redistributes salary to reflect effort. For example, a faculty member who was working 60% on Grant A ($60,000 salary) and 40% on Grant B ($40,000 salary), might have been working 50 hours per week. When Grant B ends, the faculty member reduces work hours to 30 hours and devotes all of those hours to Grant A. Grant A, in this example, is unable to fund any of the faculty member’s additional salary, so the faculty member is paid $60,000 from Grant A and is $40,000 WOS. This is an appropriate charge to the grant because 100% of the remaining activity is on Grant A.

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.

Change in Level of Effort

OMB Circular A-110 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 :

• Withdraw from the project entirely;
• 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 approved at the time of award.

This rule applies to all federal grants unless waived in writing by the sponsor.

The sponsoring agency must approve 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 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

Frequently asked questions on effort reporting can be viewed at :

http://www.washington.edu/research/maa/fec/fecfaqs.html

Susan D. Camber
Assistant Vice President
Research Accounting and Analysis

Carol Zuiches
Assistant Vice Provost for Research
Executive Director, Office of Sponsored Programs