Applies to:	Original Policy Date:	Date of Last Review:	Approved by:
Faculty, staff, students	January 31, 2017	February 10, 2022 July 2024	Dr. John Nicklow, President

Policy Owner: The Office of Sponsored Programs

Policy Purpose

Federal regulations applicable to sponsored research at colleges and universities (2 CFR 200.430, “Compensation – Personal Services”) require each institution maintain internal controls to ensure remuneration paid under sponsored programs is reasonable, conforms to established written policies consistently applied to federal and non-federal activities, and maintains standards for documentation of these expenses.

Florida Institute of Technology (Florida Tech) uses effort reporting to provide a reasonable basis for distributing salary charges among institutional activities. Since Effort Reports are the source documents to support salary charges to sponsored projects, it is essential the details are based on reasonable estimates of actual effort expended on each sponsored project and non-sponsored or Florida Tech-funded accounts.

Policy Scope

Effort directly charged or cost shared to sponsored projects must be properly recorded and verified. This applies to the PI as well as other key personnel including academic and administrative faculty, research scientists, staff, and GSAs.

Policy Statement

Florida Tech is fully committed to accurate and timely effort reporting.

In preparing applications for sponsored programs, principal investigators (PIs) are to provide reasonable estimates of the effort necessary for themselves and all key personnel to carry out the project. Consistent with federal regulations, all faculty members listed as the PI on a sponsored project must contribute some level of effort to that project to provide necessary supervision/administration, regardless of the availability of sponsor salary reimbursement. The amount of effort should reflect the time necessary to oversee all aspects of the work. PIs may not record 0% effort on a project. Any actual effort recognized in excess of sponsor salary reimbursement must be cost shared by the home department of the PI.

Procedures/Guidelines

While salary charges to sponsored projects are made initially based on the planned or estimated workload of faculty and others, the actual effort of each individual working on sponsored projects must be monitored, with charges modified as necessary based on variances between the estimated and actual effort. The Office of Management and Budget (OMB) requires a commitment of effort on the part of the PI during the period in which the work is being performed. Florida Tech requires that Principal Investigators and key personnel charge a minimum of 2.5% effort to sponsored projects during the actual period for which the effort is expended. This effort may be either directly charged or provided as pre-approved cost share on the internal budget.

Following is a partial listing of exceptions to this policy and, in these cases, no PI committed effort is required. Should you have questions about a particular program or sponsored activity, please contact OSP.

• Equipment and Instrumentation grants for acquisition, unless the PI or key personnel will have effort devoted to installation, setup, etc.
• Doctoral dissertations or other awards intended as “student augmentation” such as Fellowship/Scholarship awards.
• Training grants (e.g., T32, Mentors on K/Career Awards).
• Specific purpose awards such as travel grants, workshops, and conference support grants.
• National Science Foundation (NSF) Research Experience for Undergraduates (REU) supplements. Note that committed effort of the PI must be present on the research grant for which the REU is a supplement.
• National Institutes of Health (NIH) Minority Supplements. Note that committed effort of the PI must be present on the research grant.
• National Institutes of Health (NIH) Other Significant Contributors as cited in the agency’s SF424 Application Guide.

Definitions

Effort: The proportion of time spent on activities related to a Principal Investigator’s or employee’s duties, for which university compensation is received. Total effort must always equal 100%.

Institutional base salary (IBS) - the annual compensation paid by Florida Tech for an employee’s appointment, whether that individual’s time is spent on research, teaching or other institutional activities.

Compliance Reference

Office of Management and Budget (OMB) 2 CFR 200.430, “Compensation – Personal Services”): 2 CFR 200.430

Responsibilities

Either the individual whose effort is being reported, the PI, or a responsible person who has reasonable knowledge of the reporting individual’s activities during the period must complete Effort Reports.

The Effort Report must account for all effort covered under an individual’s institutional base salary (IBS). By definition, an individual’s total university effort must always equal 100 percent (never more or less), regardless of the number of hours worked or the appointment percentage. For the purposes of determining the institutional base salary for compliance with 2 CFR 200.430, not all activities undertaken in an individual’s professional capacity are included in activities compensated by IBS, such as external consulting.

Enforcement

Effort certification is required for every employee who receives a portion of his or her salary from a sponsored project or cost sharing account. Employees share in Florida Tech’s responsibility to report effort accurately and in a timely manner. Inaccurate effort reporting or failure to comply with effort reporting policy may result in financial penalties, expense disallowances, and damage to Florida Tech’s reputation.