Variations in Work Week
Scenario: Two faculty members work the same number of hours on a grant and are paid the same dollars, yet one faculty member works 10 hours more a week on average than the other.
- Faculty A: has an average work week of 50 hours, works 10 hours on Grant X and is paid $37,500 on the grant.
- Faculty B: has an average work week of 40 hours, works 10 hours on Grant X and is paid $37,000 on the grant.
Does this represent a smaller or larger percentage of total effort performed by the faculty working fewer hours?
- Effort on grants (and all other UW activities) is based on each faculty member's effort (hours worked) on each grant/activity divided by their total University effort (hours worked). There is no "standard" work week for faculty.Therefore, in the scenarios above, Faculty A devotes 20% time his/her grant (10 hrs./50 hrs.) and Faculty B devotes 25% time to his/her grant (10 hrs./40 hrs.).
- The percent of salary allocated to a faculty member's grant should be commensurate with the percent of their total University work effort directed towards the goals of the grant, i.e., 20% and 25% respectively for Faculty A and Faculty B above.
- Sponsors expect, and require, that the basis for salary charged to their project(s) for the effort performed be allocated consistently, i.e., on a consistent basis, as the percentage of salary charged to other activities performed by the faculty member.
- Sponsors are not to be charged at a higher rate per unit of effort than the institution pays an employee for effort towards other University activities.
Regardless of the University activities engaged in, the compensation for those efforts must be at a consistent rate.
Variations in Effort During an FEC Cycle
Scenario: A faculty member has three grants and does not provide the same amount of effort on the grants each month.
- Grant A: 25% effort commitment
- First month of cycle works 100% on Grant A
- Second month of cycle works 50% on Grant A
- Grant B: 25% effort commitment
- Second month of cycle works 50% on Grant B
- Third through sixth month of cycle works 25% on Grant B
- Grant C: 50% effort commitment
- Third through sixth month of cycle works 75% on Grant C
Is the faculty member in compliance with his/her effort commitments to the sponsors?
Over the course of the cycle, the faculty member's effort averages out to the percentage committed to the sponsor.
- Grant A: (100% + 50%)/6 months = 25%
- Grant B: (50%/6 months) + ((25%*4 months)/6 months) = 25%
- Grant C: ((75%*4 months)/6 months = 50%
Fluctuations in Effort During the Budget Period
Scenario: A PI significantly changes the percent effort by more than 25% from cycle to cycle during the budget period.
Is the PI in compliance if during one FEC cycle his/her effort is less than 25% or more of what was committed?
Normally effort should be met over the budget period, not necessarily over each FEC cycle. Effort may vary from FEC cycle to FEC cycle. As long as the PI(s) or approved project director(s) are not changed from those specified in the application or award and they do not
•reduce effort by 25% or more
•disengage from the project for 3 consecutive months or more
•make changes in the approved cost sharing.
Unless one or more of the three issues noted above apply, there is no need to request prior approval from the sponsor for fluctuations in effort.
Actual Does Not Equal Commitment
Scenario: Faculty member provides effort at a different percentage than committed
- Grant A: 25% commitment
- Grant B: 25% commitment
- Grant C: 50% commitment
Is the faculty member in compliance if s/he spends more time on Grant A than was committed and less on Grant C?
- Grant A: 50% for three months
- Grant B: 25% for three months
- Grant C: 25% for three months
The additional effort on Grant A, if not charged directly to Grant A, would be considered voluntary uncommitted cost sharing and can only be provided if there are sufficient non-grant funding sources to cover the effort above the original commitment. In this case there are no non-grant funding sources available to cover the additional effort and the effort should be reduced to 25% or the salary distribution changed to reflect the actual effort, in this case Grant A charged 50% for the 3 months.
Grant B can be funded at 25% effort and is in compliance.
Grant C has been reduced by 50%. In this scenario, prior sponsor approval may need to be obtained in writing before effort can be reduced by 25% or more depending on the percent effort devoted to Grant C for the other months the grant is active. That is, in this scenario the faculty member’s effort to Grant C for the 6 month period would be reduced to 37.5% representing a 25% reduction thereby requiring prior approval from the sponsor. However, if the faculty member devotes 50% effort to Grant C for the remainder of the grant (budget) period his/her total effort reduction to Grant C would be less than 25% thereby not requiring prior sponsor approval.
Effort Benefits Two Grants
Scenario: Faculty member spends time setting up equipment that will support two grants
- First month of FEC cycle: 100% spent setting up equipment that supports two grants.
- Grant A: 75% commitment
- Grant B: 25% commitment
How does the faculty member distribute the effort expended on setting up the equipment?
The equipment set up time should be allocated in accordance with the benefit each grant will derive from the equipment. The benefit can be based on reasonable estimates, such as:
- an objective or subjective assessment of use, such as hours of equipment usage
- faculty member's effort toward each grant
Part Time Appointments
Scenario: Faculty member has a 50% appointment and has a grant that funds 50% of his/her full time institutional base salary, i.e. all of the 50% appointment.
Does the faculty member devote 50% of 20 hours or 100% of 20 hours to the grant?
The faculty member should certify to 100% of his/her compensation being supported by the grant. This represents 50% FTE. She certifies to the compensation level, not the FTE level.
Faculty with De Minimus Activity
Scenario 1: Faculty works on average 60 hours a week and is paid 100% on sponsored reasearch. He is asked to serve on a UW instruction board which entails approximately 10 hours per year - three four hour meetings and time responding to emails/queries.
Does the faculty member need non-grant funding to cover his/her work on the UW instructional board?
The term used to identify effort that is too low to quantify is de minimus. This term does not specify nor quantify a specific number of hours or percent of effort. To decide if an activity should be considered de minimus, determine if, in aggregate, its inclusion in, or exclusion from, total effort would affect the percentages of effort allocated to grant funded activity. If it would affect the precentages of effort allocated to grants, the percentages of salary paid on the grant(s) should be adjusted commensurately, i.e. reduced in this scenario.
Scenario 2: Research faculty member is paid 100% sponsored funding and does not have teaching or administrative responsibilities. S/he is required to attend faculty and division meetings that require less than 1% of her time.
Can s/he charge the time spent attending these meetings to her grants?
There are no set parameters to define what constitutes de minimus activity. This is situational and must be determined by the faculty member in consultation with appropriate departmental leadership. As in scenario 1, the activities would be considered de minimus if they do not affect the percentages of effort allocated to sponsored activity.
100% Research Activity and Teaching
Scenario: A faculty member who is 100% sponsor funded participates in teaching activities.
Can the faculty member's grants pay for teaching activities?
Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the spensored agreements such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students and attending meetings and conferences.
If the teaching and other activities are NOT contributing and/or intimately related to the work under the agreements that are paying the salary, then a portion of the individual's salary proportionate to the non-grant effort must be paid from other non-federal sources.
Scenario: An emeritus faculty member with a 40% appointment (the maximum allowed for retired employees) has been hired to teach a course and has been asked to "volunteer" time on a sponsored reasearch project.
Is it allowable for a faculty member with a 40% appointment to volunteer some of the remaining 60% of a full time appointment?
The effort attributable to the sponsored project must be considered part of the compensation of the individual and is therefore considered part of the 40% effort allocable for retired faculty.
Salary Commensurate with Effort
Scenario: A faculty member is asked to serve on instructional committees for a joint appointing department and is requested to run an entire course. The appointing department offers 25% compensation. The estimate of the effort required to develop and deliver the course is:
- 6 months prep time at 40% effort
- 3 months effort at 50% during the quarter the course is taught
Is the compensation offered sufficient to support the effort required?
The percent of salary is not commensurate with the percent of effort required to accomplish the assignment. Additional non-grant funded salary needs to be identified to support the level of effort required.
Faculty Who Lose External Funding
If a faculty member loses external funding and there are no other funds available to fund his/her appointment, the faculty member must either go on Reduced Responsibility (RR) status or do a voluntary (permanent) FTE change. For more information please see GIM 38 Faculty Reduced Responsibility Status Involving External Funding for more details and scenarios.
Allocation of Funding for Required University Activities
Scenario: The department wants to set 5% as a common percentage of non-sponsored funding to support non-grant activity for their faculty members.
Is 5% sufficient for funding non-grant activity for faculty members in their department?
While 5% may be the right funding level for some faculty, others may work significantly more, or less, on non-grant activities. While removing everyone from grant funding for some portion of their time may reduce risk, every individual's portfolio of activities should be reviewed to determine the appropriate mix of grant and non-grant funding. The final determining factor is each individual's actual effort. While a department may elect to use a percentage of total faculty salaries for budgeting purposes, to support non-grant activity, the actual salary charged to these funds must reflect the actual effort of the faculty.
Post Award Salary Changes
Scenario: A faculty member's salary increases over 3-4% (allowed by NIH) between the time the proposal was submitted and when it was awarded.
- $100,000 salary at the time of proposal submission. 10% effort committed and $10,000 in funding requested
- $120,000 salary at the time of award. The 10% commitment now calculates to $12,000
How does the faculty member deal with the deficit? Can he reduce his effort to the budgeted dollar amount?
The focus should be on the required level of effort needed to accomplish the objectives of the project/program as it was proposed. If a reduced level of effort will not impact meeting the project/program objectives then that would be the most appropriate course of action. However, if the reduction is 25% or more of the proposed (committed) effort, agency approval will need to be obtained for the decrease in effort.
If the proposed level of effort is required and funds are not available from the award, then non-grant funding could be used to "cost share" some effort.
Committed and Cap Cost Share
Scenario: A faculty member has both a committed cost share pledge and a salary cap cost share requirement.
- 10% committed cost share pledge
- 0.7% salary cap cost share requirement
Can the salary cap cost share be included as part of the committed cost share?
Salary cap cost sharing represents the portion of salary which cannot be charged directly to the grant as it exceeds the limitation (i.e. salary cap) set by the sponsor. It does not represent additional effort that can be applied to effort based cost share commitments.
For example, a faculty member commits a total of 15% effort to a grant - 10% to be directly charged and 5% committed cost sharing and is over the salary cap.
- sponsor pays 10% of the salary cap amount
- a non-federal/non-grant funding source pays
- 10% of the difference between the salary cap and the faculty member's total salary
- 5% committed cost share
This satisfies the original effort commitment.
In the example above, the faculty member may have
- 9.3% of his/her salary paid directly by the grant
- 0.7% paid by a non-federal budget to satisfy the original 10% commitment and
- 5% funded by a non-federal, non-grant budget to satisfy the cost share commitment.
- 15% TOTAL EFFORT
Endowed Supplements and Academic Summer Salary
Scenario: A faculty member with a nine month appointment and an Endowed Supplement (ENS) component will work one summer month on a grant.
How does the faculty determine the institutional base salary (IBS) for the summer? Does it include ENS?
- During the academic year the faculty earns
- $10,000 a month on a state line
- $1,000 a month ENS
- Total monthly IBS is $11,000
- The endowed supplement would be included in the summer IBS.
This is compliant with Uniform Guidance which states that "charges for work performed by faculty members on Federal awards during periods not included in the base salary period will be at a rate not in excess of the IBS."
Re-budgeting and K Awards
Scenario 1: A faculty member has 95% effort paid on a K Award.
Can the faculty decrease their effort on the K Award to 75% and use the remaining 20% effort paid by the K Award to work on other projects that are "consistent with the objectives of the award"?
No. It is not allowable to charge payroll to a K Award for effort directed towards another project even if they are closely related.
Scenario 2: A faculty member has $75,000 in salary on a K Award and $25,000 in annual research costs.
Can the faculty re-budget from the research cost category to the salary category so that the total dollars remain the same but the salary distribution in increased to $85,000 and the research cost category is decreased to $15,000?
The National Institute of Health (NIH) does allow institutions to re-budget under Expanded Authorities within the total costs awarded to cover salary expenses provided the salary is consistent with the institution's salary scale.
Faculty with an annual (12 month) salary of $200,000 originally budgets 75% effort to a "Mentored Patient-Oriented Research Career Development (K23) Award.
K23 Awards provide for salary support from $75,000 to $183,300, the present NIH salary cap.
Because of the salary cap, the original salary awarded, i.e. chargeable to the grant, was $137,475 ($183,300 * 75%).
If the recipient is actually contributing 85% effort, then it is permissible to re-budget to accommodate the additional $18,330 in salary distribution resulting from the increased effort (85% * $183,300) provided the funds are available within the original budget award.
Care must be taken, however, as salary limits fro NIH career (K) awards are not consistent across Institutes. It is, therefore, suggested the specific NIH Institute be contacted to determine if a maximum contribution to the candidate's salary exists. It is also important to acknowledge that the salary may not exceed the NIH salary cap.