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NYU complies with federal effort reporting requirements and has implemented a system to accumulate and document personal service costs charged to sponsored programs. The system is designed to ensure that the commitment indicated in a proposal and resulting award is met and in compliance with NYU and sponsor terms and conditions. It is implemented through time and effort reports for each person whose salary is charged to a sponsored program and/or cost sharing account during the reporting period. The PI must ensure that his or her own reported effort and the effort of all other personnel directly charged or otherwise committed to the project are accurate and reflect the work actually performed on the project during each reporting period.
If the percentage of effort expended in a given effort reporting period is less than the percentage of salary charged to the sponsored project during the period, the salary charges must be reduced to reflect actual effort.
Effort is confirmed, reported and certified based on an after-the-fact reporting system. Effort reports are prepared for three time periods: Fall semester, Spring semester and Summer term.
A report of actual effort is generated using the Effort Reporting System (ERS). Each such effort report must be completed and certified in a timely manner after the department’s receipt of the period’s certification report.
The PI and any other faculty member whose salary is charged to a sponsored program is required to certify his or her individual effort reports. The PI must also certify that the effort reported by non-faculty personnel directly charged to projects is accurate and reflects the effort actually contributed during the reporting period.
The basis used to propose or commit effort should be the same as that used to calculate, report and certify effort.
It is recognized that a precise apportionment of effort across the activities performed on behalf of an institution of higher education is not always feasible. Research, teaching, clinical services and administration are often inextricably intermingled. Therefore, reliance is placed on estimates in which a degree of tolerance is expected.
For research scientists, administrative employees and faculty, there is no set number of hours that constitute total effort; rather total effort equals 100% of the University effort. The activities performed and the total amount of time to accomplish them will likely be different for each individual and may vary during the year and from year to year.
For faculty, the components of total effort are determined by the original NYU appointment letter, the NYU Guidelines on Faculty Effort and any modification stated in any subsequent letters from the Chair or Dean, for example when a faculty member takes on administrative responsibilities. Teaching, research (including clinical trials), clinical services within the Dental College and administrative activities are all services that may be performed on behalf of NYU.
Research scientists and administrative employees are generally on 12 month appointments and are assigned their responsibilities for research and their expected committed effort by the PI. For graduate students, a full-time appointment is comprised of a combination of research responsibilities and educational activities. They may be appointed on a semester or 9-month basis and may earn additional compensation for each summer month during which they are employed.
When an award is accepted, the Principal Investigator is committed to providing the level of effort specified in the proposal, subsequent budget modification, or resulting award notification, over the award period, unless sponsor policies permit otherwise. For some sponsors, a specific level of effort is also specified for other key personnel. It is expected that the proposed effort committed in a grant application will be provided to the project even when the amount approved in the NOGA is less than the amount requested, unless the sponsor has agreed to a reduction in effort. If such cases the unfunded committed effort must be treated as voluntary cost sharing and tracked in a separate account.
Temporary changes of less than 5 percent of assigned effort during a period are generally considered immaterial (except that the 1% minimum effort for PIs on federal grants must be met), and it is not necessary to report them on payroll documents. However, changes from assigned effort of 5% or more that are expected to continue or occur regularly must be reflected in the corresponding time and effort report.
With certain exceptions (including, for example, equipment & instrumentation grants, doctoral dissertation grants, faculty mentors on institutional training grants), faculty are expected to apply some level of effort to projects on which they are listed as the PI or as key personnel (1% or more or the minimum required by the program).
For faculty participating in activities not directly related to work on active sponsored programs (i.e., teaching, administrative service, grant proposal preparation), the effort assigned to federally-sponsored projects should rarely total more than 95%.
The sum of the committed effort on active projects plus the anticipated committed effort on proposed projects and the effort devoted to non-research activities may exceed 100% for a given period. However, to the extent that proposed projects are ultimately awarded, the effort on one or more activities must be reduced to ensure that combined effort does not exceed 100% for the period. The sponsor of an affected project will normally require notification if the effort reduction is significant.
The IBS for 9 month faculty is based on the 9 month base, even for faculty whose administrative duties extend into the summer. Faculty compensated for 9-month appointments are permitted to expend up to an additional 3 months of summer effort on a combination of service (paid by NYU) and one or more sponsored programs in the period beyond the academic year and earn up to 3 months of additional salary for that effort, subject to sponsor policies and the approval of the department chair and dean/provost. Three summer months’ compensation is the maximum allowable from all sources (including University funds).
A request for summer salary indicates a commitment to expend commensurate effort on the particular project during the Summer term (effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary). Faculty who receive summer salary from sponsored programs will be required to certify that the effort was expended on those projects during the summer effort period.
Effective 9/1/09, faculty may not charge 100% to federally-sponsored research during the summer or any given month during the academic year. The minimum which must be reserved for other duties is 5% per month for faculty without extra administrative duties and correspondingly more for chairs, directors and deans. (see NYU Guidelines on Faculty Effort for details on supplementary compensation for administrative duties).
Any effort which is committed in the proposal and resulting award, but not charged to the sponsor, must be documented as voluntary committed cost sharing and reported on the T&E certification, unless the deviation is within award limits or has been approved in advance by the sponsor (see “Changes in Status and/or Effort” below). The amounts identified for cost sharing are subject to review and approval by the responsible departmental and school leadership, and processed in accordance with NYU’s Institutional Cost Sharing Policy.
Per NYU’s Cost Sharing Policy, PIs may cost share 1% of their academic year time toward any single sponsored program. When no summer salary may be requested (because the PI is already 100% committed or the agency has prohibitions), up to 5% academic year effort may be cost shared with the approval of the chair and the dean. Any voluntary cost sharing above 5% on a single grant or 10% cumulatively (in the sum total of all awards) requires a justification and the written permission of the chair, dean and Senior Vice Provost for Research.
Faculty with administrative appointments, e.g., chairs, directors, deans, may receive a salary supplement in recognition of their increased responsibility. This supplement applies to the full IBS, and should not be considered compensation for the administrative service alone. Most administrative appointments also involve service during the summer which needs to be separately compensated and tracked, though the percent of effort need not be the same during the summer and during the academic year.
Certain sponsors (e.g., NIH) impose a limit or “cap” on the annual rate of pay that may be charged. Using the IBS for the academic year, the difference between the effort expended on the sponsored program and the sponsor salary cap is designated as cost sharing. On summer salary charges for faculty with 9-month appointments, the difference between the IBS and the salary cap need not be charged.
It is the PI’s responsibility to comply with federal and other sponsoring agency prior notification requirements related to changes in status and/or effort for all personnel on their projects. Federal agencies require prior notification and approval of significant changes in personnel status and/or effort of PIs (and for some sponsors, key personnel) on the projects that they sponsor.
Federal agencies define changes in status as:
Example: A PI has committed 50% effort to a project. A reduction of 25% of the committed effort would result in a 37.5% effort and would require agency approval.
During the life of the award, when required by sponsor policies, it is the PI’s responsibility to obtain University (Chair and Dean) and sponsor prior approval for such changes in status or effort. Requests for sponsor approval are conveyed through the Office of Sponsored Programs.
Unless otherwise communicated to the sponsor, the effort committed during a no-cost extension period is assumed to be consistent with the effort commitment for the immediately preceding award period. The sponsor must be notified at the time of a no-cost extension request if the effort to be expended is reduced by 25% or more than the level approved at the time of the award.
To identify potential errors and make adjustments on a timely basis, PIs and their department administrators should regularly compare the effort commitments contained in new and ongoing sponsored program budgets with Fame/Brio expenditure reports. In addition, in preparation for each effort reporting period, an additional, comprehensive review should take place for each project to identify potential adjustments. Effective 9/1/09, once effort has been certified on a sponsored program, it may not be recertified without explicit permission from the Chair, Dean and a designated official in the Controller’s Division. Changes in certification may not be implemented by a charge to the Federal government. The term “recertification” does not include the correction of failures to implement the original certification, e.g., paperwork errors or payroll adjustments which were requested, but not enacted. Requests for such corrections must be accompanied by documentation substantiating the claim.
Risk accounts need to be established through Sponsored Programs Accounting in the case of pending awards. This will avoid the need to transfer funds from a non-government to a government account once the award has been received.
ensures that effort reported during a no-cost-extension is consistent with the effort committed to the sponsor
Violations of this policy may subject faculty and other employees to disciplinary procedures, including, but not limited to:
Internal Audit conducts annual random audits of sponsored programs. Evaluation of the time and effort reporting system is part of this audit process.
Refer to the Policy on Effort Reporting for Sponsored Programs at Washington Square PDF for the effort reporting procedures.
Office of Management and Budget, Circular A-21
NIH Grant Policy Statement
|Effective Date:||June 01, 2009|
|Issuing Authority:||Pierre Hohenberg and Marty Dorph|
|Responsible Officer:||Marti Dunne and Ken Heck|
|Office Name:||Office of Sponsored Programs and Indirect Cost and Contract Office|
This document sets forth New York University’s policy on effort reporting for sponsored programs.
New York University receives funding for research and other sponsored programs through grants and contracts provided by the federal government and other sponsoring agencies. As a condition of accepting such funding, NYU must ensure that the effort expended on sponsored programs justifies the salary charged to them.
The goals of this Policy and these Procedures are to:
This Policy applies to all faculty, students and staff for whom NYU derives all or a portion of its compensation from sponsored programs, from both federal and non-federal sources. In addition, all persons involved in pre- and post-award research administration should be cognizant of its contents.
University Effort is the sum of all professional activities for which NYU compensates an individual. The chart below is illustrative of activities included and excluded from University effort.
Effort is the work or portion of time devoted to a particular activity, expressed as a percentage of University effort. Effort Reporting is the process by which effort expended on sponsored programs is documented and certified.
Activities Included in University Effort
Externally sponsored research, including seminars, delivering special lectures about the ongoing sponsored program, attending related meetings and conferences
Departmental/University research, including uncompensated participation in study sections, peer review of manuscripts, unfunded effort on externally funded projects
Instruction/University supported academic effort, including presentations to students, mentoring trainees
Clinical service effort
Administrative effort, e.g., Department Chair, Institute Director, service on institutional Committees, faculty advisory boards
Effort expended on preparing proposals
Service in external professional organizations and societies related to one’s work which is not compensated by those organizations
Activities Outside University Effort
Consulting and other outside compensated professional work, including service on scientific advisory boards compensated by external organizations
Volunteer community or public service
Veteran’s Administration compensated activities outlined in a Memorandum of Understanding
Special activities for which a bonus or other one-time compensation is paid by NYU
Institutional Base Salary (IBS) is the compensation that NYU pays an employee, whether that individual's time is spent on research, teaching, administrative and other service, patient care, or other activities. The compensation relevant in determining IBS is the amount that is guaranteed and fixed in advance by the appointment letter or employment agreement and paid through the NYU payroll system. For faculty with 9 month appointments, it is the salary base for the period 9/1 – 5/31.
Cost Sharing on a project refers to that portion of the total project not borne by the sponsor.
Cost sharing consists of three types: mandatory, voluntary committed and voluntary uncommitted. Only the first two of these are tracked and certified through the time and effort reporting system (see also NYU Cost Sharing Policy).
The difference between committed effort and effort charged to a sponsor is considered (voluntary committed) cost sharing. Cost sharing is tracked through a companion account and reported on the Time and Effort (T&E) certification as a separate charge.
Sponsored Program is an externally funded project, governed by the specific terms and conditions of the grantor. Sponsored Programs are separately budgeted and accounted for.
Notice of Grant Award (NOGA) is a document from the awarding agency that describes the award terms and conditions.
Sponsor Salary Cap is a limitation established by a sponsor (e.g., NIH) on the reimbursable rate of pay.