It is the policy of New York University (NYU, “the University”) that the University maintains systems and procedures documenting the distribution of compensation for personal services to sponsored projects in compliance with Federal regulations as defined by the Federal Office of Budget and Management (OMB) Circular A-21, Cost Principles for Higher Education (http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html). All Principal Investigators (PI’s) are required to certify their own effort as well as the effort of project staff working on their awards.
The purpose of this policy is to provide guidance 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:
● Comply with the requirements of OMB Circular A-21 regarding allowable personal service costs paid by Federally sponsored programs and which, in Section J.10, mandate implementation of an effort reporting system to distribute compensation across all of the relevant activities of research staff and to apportion allowable compensation to and between sponsored programs.
● Provide clear guidance to research faculty and staff to properly identify, verify and document personal service costs allocated to Federally sponsored programs.
● Describe how to properly track and certify effort in accordance with Federal requirements.
This Policy is applicable to all schools, departments, units and personnel of the University involved in administering sponsored awards.
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 program chartfield 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 certain effort reporting period is less than the percentage of salary charged to the sponsored project during the period, the salary charges on the sponsored project must be reduced to reflect actual effort.
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.
• 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 Excluded from 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.
• Clinical Services Effort:
Salaries from separately organized clinical practice plans are excludable from Institutional Base Salary (IBS) when they are not:
b) Set/determined by NYU; or
c) Part of the appointment contract.
• Bonuses and certain “one-time” payments for which extra compensation is paid by NYU.
Effort is 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 effort report must be completed and certified in a timely manner.
The PI and any other faculty member whose salary is charged to a sponsored program are required to certify his or her individual effort report. 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 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.
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|Effective Date:||September 01, 2013|
|Supersedes:||Effort Reporting for Sponsored Programs at Washington Square|
|Issuing Authority:||Sponsored Programs Administration; Office of Sponsored Programs|
|Responsible Officer:||Assistant Vice President for Post-Award Administration; Associate Vice Provost for Research Compliance and Administration|
University Effort: The sum of all professional activities for which NYU compensates an individual.
Effort: The work or portion of time devoted to a particular activity, expressed as a percentage of salary paid by NYU as defined by the Institutional Base Salary (IBS).
Institutional Base Salary (IBS): 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: That portion of a project or program cost that is not reimbursed by the sponsor (whether Federal or non-Federal) and as such represents a commitment of institutional resources that would otherwise be devoted to other University purposes. Normally at NYU, cost sharing involves personnel effort; however, other costs, such as equipment, may be used.
-Mandatory – may be required by the sponsor as a condition of the award and becomes an obligation once an award is made.
-Voluntary Committed – may be offered by NYU and becomes an obligation once an award is made.
-Voluntary Uncommitted – faculty effort over and above that level which is committed and budgeted for in a sponsored agreement.
Sponsored Projects: Signed awards (grant, contract or cooperative agreement) under which the University agrees to perform a certain scope of work for an external sponsor.
Salary Cap: The maximum annual rate of NYU Salary for the level of effort that can be charged to a sponsored award. Normally it is indexed to a specific government Executive pay level.