Office of Sponsored Programs
January 31, 2017
T. Dwayne McCay
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 based on reasonable estimates of actual effort expended on each sponsored project and non-sponsored or Florida Tech-funded accounts.
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.
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, at a minimum of 1% or more or the minimum required by the program. Principal Investigators are expected to charge a portion of their salary (at a minimum of 2.5%) to sponsored projects during the actual period for which the effort is expended.
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. Institutional base salary (IBS) is the annual compensation paid by Florida Tech for an employee’s appointment, whether that individual’s time is spent on research, teaching or other activities. 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. Florida Tech Consulting activities, for example, would not be included.