Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

12. Effort and Salaries

Proposing and Tracking Committed Effort

The commitment of effort made in proposals is the starting point for a significant amount of project cost. At the UR, approximately 60% of the direct cost expenditures for sponsored awards are for salaries and benefits. Commitment of effort also has significant implications for cost sharing. The following principles apply in this regard:

• UR salary is allocated on the basis of a distribution of TOTAL effort (FTE, or Full-Time Equivalent), including teaching, research activities, administrative responsibilities, etc. Total effort is NOT based on a specified number of hours (e.g., 40 hours per week) and total effort is individualized for each faculty member.
• No one has more than 100% FTE, and most Schools/Colleges require that a specified percent be reserved for non-sponsored activity.
• Effort committed in a research proposal, awarded by the sponsor, and expended on the project must be matched with an equivalent salary charge EITHER directly to the sponsor, or to a cost-sharing account, to some combination of these. These dollars then are included in UR's Organized Research base and become part of our indirect (F&A) cost rate calculation. For NIH investigators whose salary is above the current NIH cap, salary above the cap will be designated to an unrestricted account in the University's Human Resources Management System (HRMS). Effort may NOT be reduced to accommodate for the salary cap.
• UR (and its sponsors) expects a commitment of PI effort for each research proposal. Except in specified cases (such as travel or conference grants), proposals that include no PI effort will be questioned.

NOTE: The UR's cost sharing policy states that PI's are strongly encouraged to limit voluntary cost sharing of effort, and that expected benefits and sponsor review priorities should be weighed prior to making such commitments.

There are financial implications for cost sharing for the University of Rochester. Voluntary cost sharing on research awards will result in an estimated $350,000 loss in indirect cost recovery for every $1,000,000 of cost sharing.

A commitment of effort is usually made in the proposal budget, but it may also be made in the narrative or in conversation with the sponsor. When effort is committed, awarded and expended, corresponding salary must be directly charged or cost-shared.

In January 2001, the Office of Management and Budget issued a clarification of Circular A-21, confirming that voluntary uncommitted effort should NOT be accounted for separately and included in the organized research base for the calculation of indirect costs. That clarification also reinforces the expectation that PI's WILL make a commitment of effort to their research projects. Effort should be reported to the sponsor as actually devoted and charged.

In addition to the reporting of effort on individual awards, the UR is obligated by Federal regulation to certify, at least annually, that the distribution of an individual's salaried effort is reasonable in relation to the work performed. At the UR, this is done retrospectively via our Payroll Action ("turnaround") Forms. The certification of effort stated on the Forms must be signed by a person having first-hand knowledge of the actual effort performed on a sponsored project, preferably the PI. Finally, the UR is also obligated by Federal regulation to have an acceptable payroll system that adequately captures effort distribution. Our system adheres to the "Plan Confirmation System". Note that cost-shared effort (mandatory and committed voluntary) is identified via an annual fiscal year survey of cost sharing, in addition to any project specific reporting.