100% Sponsor-Funded Faculty

ECC System Notice

Daily Restart: The ECC system restarts daily at 6:30pm PST. It is expected for access to be limited or unavailable for about 15-20 minutes during this time each day. Access should be restored by 7pm daily, but system performance may be impacted on Monday's after 7pm when data for the week is loading.

Overview

Faculty who are supported 100% by sponsored awards, including cost share commitments, pose a high audit risk to the University.

If time spent on non-sponsored activities can be quantified and is 1% or more, it should be reflected as such on an Effort Statement.

Faculty should check with their department administrator and chair — especially before effort reporting — to confirm whether any non-sponsored activities require separate funding.

Department Responsibilities

Departments must ensure that faculty and staff have no required departmental activities when they are 100% supported by sponsored awards. When reviewing commitments, include cost share as part of the 100% sponsor-funded activity.

Departments must also provide non-sponsored funding to cover any non-sponsored work that is not considered de minimis (i.e. 1% or more).

The Employee Compensation Compliance system provides a report to help monitor faculty who are fully supported by sponsored awards. The report and instructions are available here.

Departments should develop a budgeting plan to fund non-sponsored activities. For example, set aside a fixed percentage of the department salary budget for this purpose. The percentage of salary charged to non-sponsored funds must reflect actual effort devoted to non-grant activities — not simply the budgeted amount.

Effort reports must “provide reasonable assurance that the charges are accurate, allowable, and properly allocated.” [2 CFR 200.430(i)(1)(i)]

What Cannot Be Charged to Sponsored Funds

The following are examples of non-research activities that must be charged to a non-sponsored funding source. This list is not exhaustive.

Proposal preparation (unless supported by a K Award or non-federally funded sponsored award and the sponsor approves proposal preparation time by published policy, or the proposal is for a non-competitive renewal)
Instruction
Administration (includes serving on committees)
Non-sponsored research
Service
Clinical activities

What Can Be Charged to Sponsored Funds

Non-research activities may be charged to sponsored projects only if they are directly related to and contribute to the goals of the research. Examples include:
Delivering special lectures on research outcomes
Writing reports and articles
Participating in relevant seminars
Attending meetings and conferences
Consulting with colleagues and/or graduate students