1316 Eﬀort Commitment: Managing Eﬀort Associated with Sponsored Projects
This policy sets forth requirements for proposing and managing effort on sponsored project awards administered by Yale University.
Purpose of the Policy
In requesting sponsored projects funding, the University must ensure that the proposed effort commitments are reasonable and conform to the University’s expectations of the Principal Investigator (PI) and key personnel. If the proposed sponsored project is awarded, the University must assure the sponsor that the effort proposed will be effectively managed within the parameters of the sponsor’s requirements and University policy.
As a recipient of sponsored awards, the University must assure sponsors that the effort expended on sponsored projects is at least commensurate with the salary charged to those projects. In addition, sponsors must be assured that compensated effort committed to a project, is provided, and that PIs and key personnel have properly accounted for effort devoted to research and other sponsored projects.
Note: Faculty with academic year appointments may not indicate uncompensated summer effort in their proposal nor may uncompensated summer effort fulfill a commitment to a sponsor. See Section 1316.5 below.
Yale University policy regarding effort commitment in preparing applications for sponsored projects funding, requires PIs to provide reasonable estimates of the percent of effort necessary to carry out the proposed project. PIs must also meet any proposed voluntary or mandatory effort commitments made to sponsors. PIs and Key personnel named in the application and/or award must obtain University and sponsor prior approval for reductions in effort when such approval is required by sponsors.
As stated in Policy 1315 Effort Reporting: Certifying Effort on Sponsored Projects, sponsors generally consider estimates of effort in proposal budgets to be commitments if such proposals are subsequently awarded. The basis for estimating proposed effort is the same as after-the-fact effort reporting – that is, the proposed or estimated effort must be expressed in relation to each individual’s total University effort.
Yale University does not typically cost share effort on a voluntary basis, consistent with its objectives of receiving fair compensation from sponsors for research and scholarly activity conducted at the University. A voluntary commitment of uncompensated effort should be made only where the competitive circumstances or perceived institutional benefit of receiving the award are deemed to be sufficiently strong to warrant the commitment. See Section 1316.5 regarding uncompensated summer effort. According to 2 CFR 200 (OMB Circular A-81), voluntary cost sharing on federal research proposals is not expected and cannot be used as a factor during merit review of applications or proposals. Voluntary committed cost sharing should not be included in the proposal unless explicitly described in the notice of funding opportunity.
Approval for voluntary committed cost sharing must be obtained from the Dean for self-support units or the Provost for FAS units prior to the preparation of the budget and budget justification.
Note: Both department chair and department business office approval is required prior to making a request to the Dean for self-support units or the Provost for FAS units.
Faculty and other key personnel are expected to meet minimum mandatory effort requirements on sponsored projects. Acceptance of an award with specified minimum mandatory effort requirements such as certain program project awards, and center or career development awards carries with it responsibility for meeting those requirements.
Faculty are expected to propose some level of sponsor supported activity or the minimum required by the program on proposals on which they are listed as Principal Investigator or key personnel 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, the faculty member and key personnel are committed to providing this level of effort over the annual budget period of the award unless sponsor policies permit otherwise.
Note: Faculty with a 9-month appointment who request and receive summer salary support from a sponsor are expected to fulfill the above minimum proposed effort requirement by directly charging the sponsored award.
Most faculty generally have responsibilities for teaching, administration, or patient care that would preclude them from devoting 100% of their time to sponsored activities. Department chairs, faculty, and department research administrators should regularly review proposed sponsored activity to assure that, if other activities required of the faculty member reduce the available effort to devote to sponsored activities, adjustments are made consistent with sponsor terms and conditions. Salary support for teaching, Yale administration, service, clinical activity, new or competing proposal preparation and institutional governance must come from non-sponsored funds unless they are specifically approved activities of a sponsored project. If any such activities are conducted that cannot be charged to sponsored activities, the actual effort devoted to those activities must be paid from non-sponsored funds.
Certain research faculty, postdoctoral appointees and staff may be charged at 100% effort to a sponsored project(s) but only in cases where no such activities (Yale administration, service, clinical activity, new or competing proposal preparation and institutional governance) exist, and therefore full effort can be committed to the award(s). However, should the need arise for such individuals to participate in any of these activities (including proposal preparation of new or competing proposals*) the actual effort committed to them must be supported with non-sponsored funds unless they are specifically approved activities of the sponsored project.
*Note: Depending on the nature of the proposal, proposal preparation effort typically ranges from 3 to 5%.
Faculty compensated for 9-month academic appointments are permitted to expend up to an additional 2.5 months of summer effort on one or more sponsored projects in the period beyond the academic year (i.e., during the summer research period) and earn up to 2.5 months of additional salary for that effort, subject to sponsor and University policies and the approval of the department chair and dean/provost.
A request to the Provost’s Office for summer salary indicates a commitment to put forth the comparable effort on the particular project during the summer, not the academic year. Effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary. Faculty receiving summer salary from a sponsored project will typically perform such work in their normal place of business unless the work being conducted is offsite and a requirement of the project.
Faculty are not permitted to indicate unpaid summer effort in a proposal to a sponsor. Because the University is not obligated to pay faculty salary during the summer, unpaid committed summer effort has no monetary value and therefore may not be included in applications as a commitment of the PI or the University.
If a faculty member has academic, administrative or other non-research responsibilities during the summer period, they may be precluded from devoting 100% effort to sponsored projects and thus from requesting 2.5 months of salary from those sponsored projects.
The 9-over-9 salary program allows participating faculty to charge up to 4.5 months of their salary to sponsored awards during the academic year, coincident with when the effort was devoted to the project. Academic year effort and corresponding salary charged to sponsored projects during the academic year is separate and apart from the effort and associated salary charged during the summer months (i.e., summer salary).
During the life of the award, when required by sponsor policies, it is the PI’s responsibility to obtain University (chair and OSP) and sponsor prior approval for absences, generally 3 months or more. In addition, a significant (25% or more from the level of effort approved at the time of award) reduction of the PI’s and/or other key personnel specifically named in the award requires the prior approval of most sponsors. If a reduction in effort commitment is made, the salary must be reduced commensurate with the reduction in effort.
Salary distribution consistent with the committed effort should begin on sponsored projects (or cost sharing) accounts concurrently with actual project effort. It is the PI’s responsibility to be aware of his/her effort commitments and to communicate any inability to meet those commitments to his/her respective business office to ensure that any necessary sponsor approvals of their reduced effort are obtained.
Whenever a significant change in effort is anticipated, faculty, department administrators, and department chairs should review activity, including clinical service, to assure there is sufficient time available to meet all obligations.
Yale University’s effort reporting process relies on payroll data to provide information on the projects to which an individual’s salary was charged during the certification period. Although the semi-annual and summer effort reporting periods may not coincide with the annual budget periods for which effort commitments are normally made, the effort reporting process offers an opportunity to consider whether the actual effort expended during the reporting period is consistent with the effort commitment.
Certain sponsors such as the NIH, (see http://grants.nih.gov/grants/policy/salcap_summary.htm) impose a limit or “cap” on the annual rate of salary reimbursement for a given amount of effort. Similarly, certain sponsors may limit the amount of salary that can be requested from a specific program; these programs, notably NIH Career Development Awards, may also carry minimum effort requirements. These salary limitations do not constitute committed cost sharing.
The PI and other key personnel must still devote the amount of effort agreed upon (within the constraints of 1316.6) irrespective of a sponsor imposed salary cap or program limitation.
Note: The National Science Foundation (NSF) normally limits salary compensation for senior project personnel on awards made by the Foundation, to no more than two months of their regular salary in any one year (Yale defines “any one year” as within a fiscal year, July to June). This limit includes salary received from all NSF funded grants. Salary is to be paid at a monthly rate not in excess of the base salary divided by the number of months in the period for which the base salary is paid. As such, proposal budgets submitted should not request, and NSF-approved budgets will not include, funding for an individual investigator or co-principal investigator which exceeds two months of their regular year salary. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice.
Effort devoted to a sponsored project usually occurs throughout the calendar year. For faculty on 9-month appointments this effort is generally paid for by the University during the academic year, while the sponsor pays their effort in the summer. Faculty with nine-month appointments who devote such effort to a sponsored project during the course of the academic year may continue to do so but only without formally committing a specific amount of academic-year effort in the proposal unless they elect to participate in the 9-over-9 program. In order to indicate the general availability of time for research during the academic year, proposals submitted to sponsors should include the following statement:
Yale fully supports the salary of its faculty holding a nine-month appointment, which they may use for research, instruction and administrative purposes. In accordance with these responsibilities, however, Yale makes no specific commitment of time or salary to this particular sponsored project during the academic year. This voluntary effort during the academic year is determined by the principal investigator and is not monitored by the University.
In general, faculty on 9-month appointments who are not enrolled in the 9-over-9 program must meet all explicit sponsor requirements for commitment of effort via summer salary. Faculty must ensure that the salary proposed for summer effort is budgeted accordingly and used for that purpose. Any deviation from this expectation requires the prior approval of the Provost’s Office.
Research faculty and postdoctoral associates with a twelve-month appointment are generally supported entirely by sponsor funds, with no explicit delineation between summer and academic year effort. Because twelve-month research faculty do not typically receive University funds for their effort, voluntary committed cost sharing of salary is generally not permitted for those individuals. All proposals must meet the requirement of paid effort supported by the sponsored award as stated in Policy 1316.3 above.
Roles & Responsibilities
- Approve mandatory and voluntary cost sharing.
- Review proposed sponsored activity to assure that other activities required of the faculty member will not conflict with the proposed effort commitment.
- Provide reasonable estimates of effort in order to carry out the aims of the proposals and fulfill other University obligations.
- Meet commitments to sponsor regarding voluntary and mandatory cost sharing.
- Comply with sponsor requirements regarding reduction in effort.
- Provide an amount of effort in proposals (unless sponsor policies permit otherwise).
- Faculty with 9-month appointments may receive an additional 2.5 months of salary support commensurate with the effort devoted from sponsored projects during the summer. All requests for summer salary support must receive prior approval of the Provost’s Office
Department Business Office
- Ensure that sponsor imposed salary caps are calculated correctly and salaries are recorded properly in a cost sharing account.
- Assist PI with the preparation of requests to sponsors regarding the reduction of effort.
- Provide PIs with salary distribution and effort commitment information to facilitate charging instructions for sponsored projects.
Office of the Provost/ Dean for Self-Support Units
- Approve voluntary committed cost sharing proposed during the preparation of the budget and budget justification by the PI/Department
- Approve the use of Academic Year Effort for Faculty with a 9-Month Academic Appointment to meet effort on a proposed sponsored award.
- Approve requests to exceed 2.5 summer salary months in order to meet effort commitments on a sponsored award.
Office of Sponsored Projects
- Ensure that proposals submitted to sponsors are reviewed in accordance with the requirements of this policy and the sponsor.
- Review awards to ensure that appropriate cost sharing accounts are created for both mandatory and voluntary committed cost sharing.
- Review and approve University requests for reductions of effort as required by sponsor terms and conditions.