sponsored project effort on summer and part-time appointments pamela a. webb 02.18.2010 proposal
TRANSCRIPT
Sponsored Project Effort on Summer and Part-Time
AppointmentsPamela A. Webb
02.18.2010
Proposal
Goals
Remove conservative position in existing Effort Certification policy that does not permit proposal writing on unpaid time
Clarify summer effort obligations◦ Clarify what activities are allowable while paid on
sponsored projects ◦ Establish 2.5 month paid summer salary maximum on
sponsored projects but allow exceptions when all parties understand obligations
Reduce risk of audit findings/disallowances
DRAFT POLICY - FEEDBACK REQUESTED
Recent Audit Findings Yale
◦ Summer Salary Charges did not equate to effort devoted
◦ 100% summer salary changed but non-grant activities (proposal preparation, vacation, other departmental duties) were conducted as well as grant activities
UC San Diego◦ Proposals written on grant-funded time◦ Violations of NSF 2 Summer months rule
UC Berkeley ◦ 2% of salaries were for activities not benefitting the
project
Two-prong approach
Update EffortCertification
Policy
Create Summer Effort and Part-
Time Appointment
Policy
Proposed Changes to Wording in Effort Certification Policy
“The effort statement must accurately reflect the time PIs spent preparing proposals and conducting other administrative work. Therefore they cannot certify 100% effort on sponsored projects unless they are on sabbatical, are on a less than full time appointment, or have an approved exception from their teaching and other duties. “
[proposed new wording in red]
Allowability of Costs while Charging Effort on a Sponsored Project
Allowable * Direct effort for the project’s
activities Delivering special lectures about
specific aspects of the ongoing activity
Writing reports and articles Participating in appropriate
seminars Consulting with colleagues and
graduate students Attending meetings and
conferences
Unallowable** Preparing/submitting competitive
proposals, including developing data for those proposals
Working on other sponsored projects
Vacations Attending department/school
faculty meetings Teaching or teaching preparation Administrative work/university
service Working with students not
involved in the sponsored project** does not include de minimis activity (e.g. brief consultation with graduate students not working on the sponsored project(s), handling an occasional non-project-related phone call or email, or attending a short, rare administrative meeting).
* OMB A-21, Section J.10.a. requires that such charges meet the rest of reasonableness and must be for “activities contributing and intimately related to work under the agreements”
Summer Effort and Part-Time Appointment Policy Clarifies allowable activities while charging time
to a sponsored project Formally allows voluntary proposal-writing on
unpaid time Sets a maximum of 2.5 funded summer months
on a sponsored project ◦ Other .5 month may be vacation or non-sponsored
funded work◦ Allows for exceptions when all parties agree
Expects faculty to be generally on-site in summer except when they are engaging in off-campus duties or have permission of their unit head◦ Reduces audit risk and public perception issues
Known Issues
“But I already have 3 months summer salary funded on my grants. Do you seriously expect me to GIVE IT UP?????” ◦ Request an exception from your unit head (then 3
months of summer salary are allowed)◦ Rebudget to cover other needed expenses on
your award(s) (assuming terms of award permit)◦ Save that unused salary and use it during some
other time period on the grant, or request a no-cost time extension
Known Issues (cont’d)
“I don’t have any non-sponsored funding to pay for my other two weeks … what am I supposed to do?” ◦ Discuss alternatives with your unit head
Can you time-shift some university duties normally done during the academic year to the summer, thus allowing your sponsored project to be charged during the academic year, and have non-sponsored funding available for the summer?
◦ Take vacation
Known Issues (cont’d)
“I can do my research anywhere – I don’t need to be on campus – who are you to tell me where I can and cannot work? “◦ Explain that to your unit head, and document his/her
concurrence for the project file. This meets the policy’s requirements for an exception.
Most sponsored projects involve students and other staff who need to be supervised in their activities. Many involve facilities or other resources (libraries, colleagues, equipment, etc.) that must be available. Documenting the file shows that issues of supervision and access to needed resources have been proactively addressed. This will help the University address questions raised by auditors or others who might question why a PI is receiving 3 months summer salary while not in his/her academic work location.
Known Issues (cont’d)
“What percentage of time do I have to be unpaid to be allowed to write my grant proposals. Will 2% work? ◦ It would be unusual to have a percentage of summer time less
than 5% per proposal (if you work a 40 hour work week, this would mean 3 working days were spent researching, writing, and submitting the proposal and you did no other non-sponsored activities during that time.) While we have not specified a minimum percentage, whatever you select must be “reasonable” in light of the volume of work that needs to be performed. A very low unpaid percentage (less than 5-10%) is likely to be questioned by auditors, especially if a PI submits multiple or highly complex proposals during or immediately following the summer period.
Next Steps Incorporate feedback into final draft
◦ CRAD (Nov 2009)◦ Senate Research Committee (Feb 2010)◦ OVPR senior staff (ongoing)◦ Departmental research administrators (now!)◦ GMUN and CA Advisory Groups (February)◦ Other designated groups (e.g, Twin Cities
Deans, Research Compliance Committee, etc.)
Decide on implementation schedule Obtain formal 30 day policy reviews Implement
Request to GMUN Members Review policy, form, and FAQ drafts and
provide feedback to Pamela Webb by February 22, 2010.