Effort on Sponsored Program Activities, Policy on

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Title: Effort on Sponsored Program Activities
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: All Faculty, Staff, and Students
Campus Applicability: All campuses
Effective Date: January 24, 2020
For More Information, Contact Office of the Vice President for Research, Sponsored Program Services
Contact Information: 860-486-3622 (Storrs and regional campuses)

860-679-4040 (UConn Health)
Official Website: https://ovpr.uconn.edu (Storrs and regional campuses)

https://ovpr.uchc.edu (UConn Health)

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

All faculty, staff, and students at the University of Connecticut and all regional campuses, and UConn Health (“University”).

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 activities such as 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/or 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 the specific dollar amount of the employee’s compensation and may 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, or UConn sources.

Uncommitted Effort: Any portion of ‘University effort’ devoted to a sponsored activity that is above the amount committed in the proposal and/or 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. This effort must be paid by non-sponsored University sources.

POLICY STATEMENT

This policy establishes the effort requirements for sponsored programs.

Federal Sponsored Awards:

Investigators 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, Co-Investigator or other roles as required by the sponsor 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, either through direct charge or cost shared 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’ during some portion of the sponsored award or the minimum amount required by the sponsor.  Notwithstanding the foregoing and in accordance with OMB Clarification Memo, at least 1% of a senior faculty (or researcher) effort must be devoted to the project throughout the life of the award.

Non-Federal Sponsored Awards: 

University of Connecticut and Regional Campuses: The University does not require a minimum amount of effort except in cases required by the sponsor. However, Principal Investigators must ensure they have time available to complete the project that does not overlap or conflict with their effort commitments to other sponsors or their University responsibilities.

UConn Health Campus:  The minimum amount of effort committed to a specific non-federal sponsored activity may be no less than 1% of the employee’s ‘University effort’ during some portion of the sponsored award or the minimum amount required by the sponsor.

All Sponsored Awards:

Beyond the minimum amounts specified above, the specific amount of effort committed to a particular sponsored activity is left to the judgement of the individual devoting effort to the project and the Principal Investigator/Project Director, based on his or her estimate of the effort necessary to conduct the project.

Prior sponsor approval for a decrease in effort must be obtained prior to a reduction in effort if and when sponsor approval is required as determined by the sponsor’s terms and conditions.

ROLES AND RESPONSIBILITIES

Principal Investigator:

  1. The Principal Investigator is responsible for ensuring that the minimum level of effort required by this policy, 2 C.F.R. Part 200 (federal awards) and the requirements of the sponsor are met.

All Faculty and Investigators:

  1. Devote time commensurate with effort on each project, ensure that the effort does not conflict with commitments to other sponsors or University responsibilities and is in accordance with University policy.

Department Administrators/Fiscal Officers:

  1. Regularly review faculty/investigator effort on sponsored awards to ensure it meets with the requirements of this policy.
  2. Inform Sponsored Program Services if effort commitments may not be met.

Sponsored Program Services:

  1. Provide guidance and assistance to faculty, investigators and department administrators on this policy.
  2. Review changes to payroll allocations (UConn Health Campus) and effort reports (University of Connecticut and Regional Campuses).

 
ENFORCEMENT

Violations of this policy or associated procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, the University of Connecticut Student Code, other applicable University Policies, or as outlined in any procedures document related to this policy.

PROCEDURES/FORMS

Related Information:

See NSF Cost Sharing Policy Guidance

POLICY HISTORY

Policy created:

Approved by the President’s Cabinet on 09/12/2019. This new policy combines two previous policies at Storrs and UConn Health.

History: 

Storrs Policy, “Minimum Effort on Sponsored Program Activities”, created on 3/1/2013 and revised on 7/7/2015, as approved by the Vice President for Research

UCH Policy 2008-05, “Senior/Key Personnel & Committed Effort”, created on 12/16/08 and revised on 10/8/13