Faculty and staff supported 100% from sponsored funds, including cost share commitments, pose a high audit risk to the University. While it is acknowledged that many of the UW's faculty and staff truly devote 100% of their time to sponsored awards, it is highly recommended they periodically consult with their department administrator and chair to discuss and determine if effort performed on non-sponsored activities, though seemingly incidental, is significant enough to require the department to provide non-sponsored funds to cover these activities.
The following provides examples of activities which need to be funded by non-sponsored sources and those activities that may be funded by sponsored funds. Note, these are merely examples and do not represent an all-inclusive list.
Activities that require non-sponsored funding:
Proposal preparation (unless supported by a K Award or non-federally funded sponsored award and the sponsor approves proposal preparation time by published policy.)
Instruction
Administration (includes serving on committees)
Non-sponsored research
Service
Clinical activities
Non-research activities that may be charged to sponsored projects (these activities must be directly related to and/or contribute to the goals of the research):
Delivering special lectures regarding aspects of research outcomes
Writing reports and articles
Participating in appropriate seminars
Attending meetings and conferences
Consulting with colleagues and/or graduate students
Departments are responsible for oversight to ensure faculty and staff members have no required activities in the department when they are 100% supported by sponsored awards. When reviewing faculty and staff commitments, consider cost share as part of the 100% sponsor-funded activity.
In addition, departments are responsible for providing non-sponsored funding to cover any non-sponsored work that is not considered de minimus.
It is highly recommended departments develop a budgeting plan for the purpose of funding the non-sponsored activities noted above. For example, one plan could be to set aside a specific percentage of the department budget for faculty salaries to cover these activities. It is important to note that this approach would only apply to the budgeted amount. The percentage of salary charged to non-sponsored funds should represent the actual effort devoted to the non-grant activities.
As a reminder, Effort Reports must “provide reasonable assurance that the charges are accurate, allowable, and properly allocated.” [2 CFR 200.430(i)(1)(i)]