Are all principal investigators and co-principal investigators expected to direct charge a minimum of 2%? What is the 2% minimum effort supposed to cover?
No. A minimum of 2% effort is required for the life of the project or activity by the individual that is responsible for management of the overall project or activity. On larger, multi-investigator projects, this responsibility may be shared among multiple individuals and may even require more than 2% effort to effectively manage the project or activity. Project management can include “…managing restrictions on facilities or personnel due to export controls, providing proper management of funds, submitting all required technical reports and deliverables on a timely basis, and properly disclosing all inventions to the University’s Technology Transfer Office, in accordance with Federal or contractual terms and University policy.” (Excerpt from PI Certification on ESF in EIPRS)
Does the 2% minimum effort requirement apply only to the academic year or can my summer effort count toward the 2% minimum as long as it is within the project period?
The two percent minimum effort requirement must occur within the project period. It is not limited to the academic year. The OMB A-21 clarification memo specifically states “This effort can be provided at any time within the fiscal year (summer months, academic year, or both).” The caveat is that the effort must be charged in the period in which it is expended.
If there is salary release generated due to this policy, will the funds be held at the central administration level?
No. If there is salary release generated it will remain with the college, department, or unit.
So, when the 2% direct charge effort (salary dollars) are released who controls how they will be used?
The department, college or unit maintains control and funds are used at their discretion. Procedures and practices vary across units within the University.
If I meet the four criteria to convert my effort from direct charge to voluntary committed cost share (APM Chapter 45.22 D-2), what do I have to do?
Two percent of your effort over the life of your project must then be cost shared to your project from effort funded by the state or other unrestricted funds. The cost share will be included on the main page of the ESF in EIPRS as part of your overall percent of effort. When awarded, the cost share you committed will be put on your PAR in the period in which the effort will be expended. You will then certify that the effort was appropriately expended during that period.
Would there ever be a case where an exception is granted to the policy so that I do not have to direct charge my effort or convert my effort to cost share? If so, what is the process for getting a waiver?
Yes. See APM Chapter 45.22 Section D-1 that indicates “If the sponsor and program do not expressly allow the charging of faculty salary (e.g., grants for equipment, travel, dissertation support, [and] conference support) this requirement will automatically be waived and a specific cost share waiver form is not required. If you believe that your project does not require committed faculty effort but the sponsor does not expressly disallow the charging of faculty salary, you can fill out a waiver and submit it to the Vice President for Research and Economic Development for review and approval. The cost share waiver form will be located at www.uidaho.edu/research.
What if my grant has a mandatory match or cost share requirement and I use at least 2% of my effort paid for by state funds (or other unrestricted funds) as match? Do I still have to direct charge 2%?
No. If the sponsor has a mandatory cost share or match requirement and you match/cost share at least 2% of your state funded effort, the minimum effort requirement has been met.
Some people have scrutinized this policy and done their homework. It was disingenuous of ORED to conveniently omit some text in the OMB Circular, which states: “In addition, most federally funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the federal government.” Why did the University choose to omit the option of “unpaid” effort by the sponsor in APM Chapter 45.22 D-1?
The University did not omit the option of unpaid effort but made a conscious decision to seek direct payment from the sponsor first before utilizing state or other unrestricted funding to satisfy the minimum level of committed effort required on all projects. The 2001 OMB Circular A-21 clarification document cited in section D-2 of APM Chapter 45.22 does include the sentence listed above. However, it is necessary to read the entire paragraph to understand it in context. The rest of the paragraph reads:
“This effort can be provided at any time within the fiscal year (summer months, academic year, or both). Such committed faculty effort shall not be excluded from the organized research base by declaring it to be voluntary uncommitted cost sharing. If a research program [or] research sponsored agreement shows no faculty (or senior researchers) effort, paid or unpaid by the federal government, an estimated amount must be computed by the University and included in the organized research base. However, some types of research programs such as programs for equipment and instrumentation, doctoral dissertations and student augmentation do not require committed faculty effort, paid or unpaid by the federal government and consequently would not be subjected to the adjustment.”
This paragraph clarifies that the federal government requires a minimum level of effort to be directly attributed to the project costs either by directly charging the sponsor or by converting the effort to voluntary committed cost share that must be tracked and accounted for in our accounting system. Understanding the economic impact to the University of using direct charge effort, voluntary committed effort and voluntary uncommitted effort is essential. Direct charge effort allows the University to recover some of the cost and release University dollars back to the college, department, or unit. Converting the effort to voluntary committed (when direct charging is not allowed) uses state or other unrestricted dollars AND results in movement of those same dollars into the direct research expenditure category ultimately leading to a lower F&A rate for all research.
Voluntary uncommitted effort is effort that takes place on a project that is not quantified or disclosed to the sponsor. The OMB Circular A-21 clarification memo says, in essence, that the federal government recognizes that institutions put forth effort they are not compensated for. This effort does not have to be tracked nor is it converted to direct research dollars. However, OMB Circular A-21 also says that a project must have some level of committed, tracked and reported effort by the principal investigator. All effort on a project cannot be voluntary uncommitted effort because it would allow an institution to artificially reduce the direct research expenditure base, thereby increasing the F&A rate.
How does this minimum effort requirement relate to my position description?
All activities engaged in should be represented accurately by overall percentage of effort in each category (scholarship and creative activities, teaching and mentoring, outreach and extension, etc.) of an individual’s position description regardless of funding source. You should check with your college and unit administrators to see if your activity necessitates amending the allocation of effort in each category according to the disciplinary standards of your unit(s). When direct charging of effort to the sponsor is not possible and voluntary committed cost shared effort must be used, the effort expended on state or unrestricted funds must be allocated to the project through the cost share mechanism of the University. This allocation of effort then changes the remaining effort available for responsibilities listed in your position description. It will reduce time available to cost share on subsequent projects.
Doesn’t the effort listed in the ESF represent a proposed allocation of effort and then the PARs accounts for the actual effort?
Yes, that is correct. The main page of the ESF in EIPRS asks you to disclose all of the effort you plan to devote to the project during the project period—including effort that is direct charged and cost shared (mandatory, voluntary committed and voluntary uncommitted). The distribution of your effort on your PAR (effort report) comes directly from the payroll ledger in the University of Idaho accounting system. If you cost share your effort, college, departmental, or unit personnel enter the amount that each individual has indicated they were going to cost share during the reporting period in to the PAR system. The PAR then recalculates your effort to include the cost shared effort and requests that you confirm that you expended the effort as reported on the PAR.
Given the federal process for effort reporting is under review, why make any changes now?
The OMB Circular A-21 clarification memo addresses the need for a minimum level of effort required on all federal projects. The federal regulation that may change in the future relates solely to the administrative requirements regarding certification of effort, not the actual charging of the effort itself.
Why was this policy created?
The administrative procedure was created to:
- Define who is eligible to be a PI/CO-PI at UI; and
- Give unit leaders (Deans, Department Heads or Leaders of other official units) the authority and responsibility to certify the capacity of individual(s) who are proposed to function as a PI or Co-PI on a project by project basis; and
- Ensure that when multiple individuals are involved as investigators on a project, a clear description of roles for each is included at the development stage; and
- Provide a record for individuals of their responsibilities which can be accessed and used in the promotion and tenure and yearly evaluation processes; and
- Direct (or facilitate) proposed PIs to strategically plan the actual efforts they will invest in managing and coordinating a project as well as the effort they will put into the research or creating refereed, juried or other outputs; and
- Modify overhead distribution criteria so that the distribution to colleges and entities is based upon the percentage of effort of the PI and Co-PIs unless modified by the relevant deans and Vice President for Research and Economic Development; and
- Follow Memorandum 01-06 “Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs” specifically related to ensuring a minimum level of committed effort.
Did this APM policy have faculty and staff input as it was developed?
The proposed administrative procedure was submitted to University Research Council in draft form for review and comment multiple times beginning in early December, 2010 thru April, 2011. The research council reviewed, discussed and modified the proposed procedure prior to its final submission and agreed to move the final version forward to the APM approval process in late March. The procedure review was completed by legal counsel in June, 2011. On June 28, 2011 it was submitted to the policy tracking and approval process. Its broad review was completed on October 28, 2011. It was submitted to Faculty Senate as an information item as required in October of 2011. No input or comment was received from Faculty Senate. The APM addition was completed and became operational January 1, 2012.