Sponsored Project Effort on Summer and Part-Time Appointments Pamela A. Webb Proposal

 Remove conservative position in existing Effort Certification policy that does not permit proposal writing on unpaid time  Clarify summer effort obligations ◦ Clarify what activities are allowable while paid on sponsored projects ◦ Establish 2.5 month paid summer salary maximum on sponsored projects but allow exceptions when all parties understand obligations  Reduce risk of audit findings/disallowances

 Yale ◦ Summer Salary Charges did not equate to effort devoted ◦ 100% summer salary changed but non-grant activities (proposal preparation, vacation, other departmental duties) were conducted as well as grant activities  UC San Diego ◦ Proposals written on grant-funded time ◦ Violations of NSF 2 Summer months rule  UC Berkeley ◦ 2% of salaries were for activities not benefitting the project

Update Effort Certification Policy Create Summer Effort and Part- Time Appointment Policy

“ The effort statement must accurately reflect the time PIs spent preparing proposals and conducting other administrative work. Therefore they cannot certify 100% effort on sponsored projects unless they are on sabbatical, are on a less than full time appointment, or have an approved exception from their teaching and other duties. “ [proposed new wording in red]

Allowable *  Direct effort for the project’s activities  Delivering special lectures about specific aspects of the ongoing activity  Writing reports and articles  Participating in appropriate seminars  Consulting with colleagues and graduate students  Attending meetings and conferences Unallowable**  Preparing/submitting competitive proposals, including developing data for those proposals  Working on other sponsored projects  Vacations  Attending department/school faculty meetings  Teaching or teaching preparation  Administrative work/university service  Working with students not involved in the sponsored project ** does not include de minimis activity (e.g. brief consultation with graduate students not working on the sponsored project(s), handling an occasional non-project-related phone call or , or attending a short, rare administrative meeting). * OMB A-21, Section J.10.a. requires that such charges meet the rest of reasonableness and must be for “activities contributing and intimately related to work under the agreements”

 Clarifies allowable activities while charging time to a sponsored project  Formally allows voluntary proposal-writing on unpaid time  Sets a maximum of 2.5 funded summer months on a sponsored project ◦ Other.5 month may be vacation or non-sponsored funded work ◦ Allows for exceptions when all parties agree  Expects faculty to be generally on-site in summer except when they are engaging in off-campus duties or have permission of their unit head ◦ Reduces audit risk and public perception issues

 “But I already have 3 months summer salary funded on my grants. Do you seriously expect me to GIVE IT UP?????” ◦ Request an exception from your unit head (then 3 months of summer salary are allowed) ◦ Rebudget to cover other needed expenses on your award(s) (assuming terms of award permit) ◦ Save that unused salary and use it during some other time period on the grant, or request a no- cost time extension

 “I don’t have any non-sponsored funding to pay for my other two weeks … what am I supposed to do?” ◦ Discuss alternatives with your unit head  Can you time-shift some university duties normally done during the academic year to the summer, thus allowing your sponsored project to be charged during the academic year, and have non- sponsored funding available for the summer? ◦ Take vacation

 “I can do my research anywhere – I don’t need to be on campus – who are you to tell me where I can and cannot work? “ ◦ Explain that to your unit head, and document his/her concurrence for the project file. This meets the policy’s requirements for an exception. Most sponsored projects involve students and other staff who need to be supervised in their activities. Many involve facilities or other resources (libraries, colleagues, equipment, etc.) that must be available. Documenting the file shows that issues of supervision and access to needed resources have been proactively addressed. This will help the University address questions raised by auditors or others who might question why a PI is receiving 3 months summer salary while not in his/her academic work location.

 “What percentage of time do I have to be unpaid to be allowed to write my grant proposals. Will 2% work? ◦ It would be unusual to have a percentage of summer time less than 5% per proposal (if you work a 40 hour work week, this would mean 3 working days were spent researching, writing, and submitting the proposal and you did no other non-sponsored activities during that time.) While we have not specified a minimum percentage, whatever you select must be “reasonable” in light of the volume of work that needs to be performed. A very low unpaid percentage (less than 5-10%) is likely to be questioned by auditors, especially if a PI submits multiple or highly complex proposals during or immediately following the summer period.

 Incorporate feedback into final draft ◦ CRAD (Nov 2009) ◦ Senate Research Committee (Feb 2010) ◦ OVPR senior staff (ongoing) ◦ Departmental research administrators (now!) ◦ GMUN and CA Advisory Groups (February) ◦ Other designated groups (e.g, Twin Cities Deans, Research Compliance Committee, etc.)  Decide on implementation schedule  Obtain formal 30 day policy reviews  Implement

 Review policy, form, and FAQ drafts and provide feedback to Pamela Webb by February 22,