Unlike time spent preparing new and competing renewal grant proposals, the time spent on non-competing proposals, supplements and extensions involves reporting work on the existing grant period and therefore does not require non-sponsored funding.
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Effort Policy Questions
Should faculty be paid on non-sponsored funds for time spent preparing non-competing proposals, supplements and extensions?
What are faculty effort certification reports (FECs) and who must complete them?
It is a federal requirement that all salaries charged either directly to a federally funded sponsored agreement and/or to non-sponsored sources for the fulfillment of a cost-share commitment being met via faculty effort not charged directly to the sponsored agreement, be supported by records that provide assurance that the charges reasonably reflect the work performed. The UW meets these requirements via the faculty effort certification reports (FECs).
FECs are semi-annual reports designed to meet the federal requirements described above. Thus, a faculty member will receive, and must complete, an FEC if he or she is paid by the University of Washington and
- Performs effort paid on federal and/or nonfederal sponsored projects; and/or
- Performs cost-sharing on federal and/or nonfederal sponsored projects.
Do the rules on salary allocation and funding non-sponsored activity including proposal preparation still apply to faculty who have secured grants from a non-federal sources?
The UW’s effort certification guidelines are based on federal Uniform Guidance, 2CFR 200.430. These regulations pertain to faculty whose salary is funded in any part with federal sponsored funds. The guidelines do not apply to faculty with salary supported only with non-federal sponsored funds. Faculty should follow the non-federal sponsor’s policy, if any.
Who needs to certify faculty effort?
While technically a federal requirement, the UW presently requires this certification for all sponsored agreements regardless of funding source.
If the chair / director / unit head does not have the resources (or has allocated those resources to other competing priorities) to cover the costs of proposal preparation, what options are available to faculty members?
There are limited options when this occurs. One option is to identify an alternative funding source such as a gift budget to cover the cost. Also, in consultation with and concurrence from the unit head, if the faculty is involved in multiple scholarly (non-sponsored) activities, he/she could examine the possibility of rebalancing those efforts to allow time for proposal preparation or reducing time spent on some non-sponsored activities.
Another potential option is associated with Faculty Reduced Responsibility (RR) Status (GIM 38). This option, which includes the option to volunteer time for scholarly activity including proposal writing, is only available for faculty who have temporarily reduced their institutional responsibilities commensurate with a reduction in the amount of their institutional base salary (IBS) resulting from a loss in external funding. The faculty member must be on approved RR status to utilize this option.
Why do faculty need to certify their effort on various activities?
The federal government requires that charges to federal awards for salaries and wages be based on records that represent a reasonable approximation of the work performed on those federal awards relative to the total activity for which the University compensates the faculty member. As part of meeting this requirement, faculty review and certify their effort.
What implications arise from inaccurate certification of faculty effort?
Charging and certifying salaries that are not properly supported could lead to audit findings, disallowances, fines, suspension and debarment, as well as other sanctions at the institutional and/or individual level.
What types of activities are faculty required to track and certify?
The purpose of the FEC is to certify that the compensation (institutional base salary) charged to each sponsored agreement is reasonable in relation to all other compensated UW activities. Thus, faculty completing FECs must take into consideration research, instruction, administration, service and clinical activity (excludes clinical incentive payments). See GIM 35.
What types of activities are included in one’s institutional salary?
Institutional base salary (IBS) is the annual compensation, including A/B salary as it relates to tenured faculty, paid by the University of Washington for an employee’s appointment, whether that individual’s time is spent on research, instruction, administration, service or clinical activity. IBS excludes any income that an individual is permitted to earn outside of duties for the University of Washington.
The components of IBS are base salary (regular salary, summer salary, paid professional leave and salary for retired faculty); administrative supplements (ADS); endowed supplements (ENS); and clinical salary (UW Physicians (UWP) and Children’s University Medical Group (CUMG)). Note, clinical incentive salaries are excluded from IBS.
How do faculty calculate their time and effort on these various activities?
A faculty work week is composed of the average number of hours a faculty member normally works during a week. Hours are to be averaged over the effort reporting period. For many faculty members, this number will vary from one week to another; there is not a standard 40-hour work week for faculty.
Example: If, within a six-month cycle, a faculty member worked thirteen 60-hour weeks and thirteen 40-hour weeks, his/her average work week would be 50 hours. Hours are averaged over the six-month effort reporting cycle.
Faculty are not required to keep track of hours on a daily or even weekly basis. They are, however, expected to estimate, as a percentage of their total compensated (IBS) effort, that what they do on an average per week, regardless of the actual number of hours worked, days of the week or hours of the day, over the reporting period is reasonably reflected on their FEC report. This allows them to certify in good faith that their effort compensated on a sponsored project is reasonable.
If federal grants cover 80% of a faculty member’s salary and other UW sources (e.g. gift, state funds) cover the other 20%, what activities can he/she engage in with that other 20% time?
This other 20% time is considered “non-sponsored” time. Salary support from non-sponsored funds may be used for activities such as teaching, administration, service, clinical activity, institutional governance and preparing new and competing renewal proposals. In addition, it may be used to fund cost shared effort commitments, i.e., effort devoted toward a sponsored project that is charged to other UW non-grant sources.
What counts as de minimis effort?
For effort certification purposes, University of Washington activities whose inclusion in or exclusion from total effort would not, in the aggregate, affect the percentages of effort allocated to sponsored activity, and therefore do not require separate tracking and funding.
Should faculty be paid on non-sponsored funds for time spent preparing new and competing grant proposals?
Yes. Time spent preparing new and competing renewal grant proposals represents an official University activity normally covered under one’s institutional base salary using non-sponsored funding in an amount proportionate to one’s total FTE. Note, see the Reduced Responsibility FAQ section for exceptions.