Minimum Effort on Sponsored Program Activities

Title: Minimum Effort on Sponsored Program Activities
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: Faculty and key personnel on sponsored proposals and awards
Campus Applicability: All campuses except UConn Health
Effective Date: July 7, 2015
For More Information, Contact Office of the Vice President for Research, Sponsored Program Services
Contact Information: (860) 486-3619
Official Website: http://research.uconn.edu/

 

REASON FOR POLICY

Effective January 5, 2001 by Presidential Review Directive and clarification memo issued by the Office of Management and Budget (OMB) to 2 CFR Part 220 (as codified from Circular A-21) and most recently OMB Uniform Guidance 2 CFR Part 200, it is expected that “most Federally-funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the Federal government. This effort can be provided at any time within the fiscal year (summer months, academic year, or both).” The clarification memo also states that, “…Some types of research programs…do not require committed faculty effort, paid or unpaid by the Federal government…

The National Institutes of Health (NIH) Grants Policy Statement asserts that “‘zero percent’ effort or ‘as needed effort’ is not an acceptable level of involvement for ‘key personnel.’

The National Science Foundation revised its policy effective January 18, 2011 stating that except when required in an NSF solicitation, inclusion of voluntary committed effort cost sharing is prohibited.

APPLIES TO

This policy applies to all Principal Investigators, Co- Principal Investigators, and Co-investigators on Federal sponsored program proposals or awards at the Storrs campus and regional campuses.

DEFINITIONS

University Effort: The portion of ‘total professional effort’ that comprises one’s professional/professorial workload at UConn for which the employee is compensated.  This includes research, instruction, other sponsored activities, administration, non-sponsored/departmental research, university service, competitive proposal preparation and clinical activities.

Committed Effort: Any part of ‘University effort’ that is quantified and included in a sponsored program proposal and the subsequent award (e.g., two summer months, 12% time, one half of a year, three person-months, etc.).  This quantified effort/time is associated with a specific dollar amount of the employee’s compensation.

Associated effort and funding to support this devoted effort/time can be in the form of:

Direct Charged Effort:  Any portion of ‘committed effort’ toward a sponsored activity for which the sponsor pays salary/benefits.

Cost Shared Effort:  Any portion of ‘committed effort’ toward a sponsored activity for which the sponsor does not pay salary/benefits, which instead are paid using other, non-federal, UConn sources.

Uncommitted Effort: Any portion of ‘University effort’ devoted to a sponsored activity that is above the amount committed in the proposal and the subsequent award.  This ‘extra’ effort is neither pledged explicitly in the proposal, progress report or any other communication to the sponsor nor included in the award documentation as a formal commitment.

POLICY STATEMENT

This policy establishes the minimum effort requirements as those which are specified by the funding source (federal or non-federal), regulation, and the specific required minimum levels directed by the sponsor in the notice of application or solicitation.

Federal Sponsored Awards:

Faculty are expected to propose some level of sponsor supported effort or the minimum required by the program on proposals on which they are listed as Principal Investigator, Co-Principal Investigator or Co-Investigator unless specifically exempted by the sponsor.  (Examples of exceptions to the minimum proposed effort requirement would possibly include doctoral dissertations, equipment and instrumentation grants, travel grants, and conference awards.)  If an award is accepted, these personnel are committed to providing this level of effort over the annual budget period of the award unless sponsor policies permit otherwise.

The minimum amount of effort committed to a specific federally sponsored research activity may be no less than 1% of the employee’s ‘University effort.’  Beyond this minimum, the specific amount of effort committed to a particular sponsored activity is left to the judgment of the Principal Investigator/Project Director, based on his or her estimate of the effort necessary to meet the technical goals and outcomes of the project

Non-Federal Sponsored Awards: 

The University does not require a minimum amount of effort except in cases required by the sponsor.

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Conduct Code.

PROCEDURES/FORMS

Related Information:

See NSF Cost Sharing Policy Guidance

POLICY HISTORY

Policy created:  3/1/2013

Revised:           7/7/2015 (approved by the Vice President for Research)