Effort Commitment and Reporting

9.9 Effort Commitment and Reporting
As a condition of receiving funding from the federal government, the University maintains a system of reporting effort devoted to sponsored projects, which allows responsible individuals to certify the portion of their effort and salary devoted to each sponsored project activity. Outlined below are some of the significant points of BU’s Effort Reporting policy.

9.9.1 Committing Effort

At the time of proposal development, the PI/PD prepares a budget in which he/she determines the percent of effort or person months needed for each of the positions proposed to work on the project. In preparing such a budget and managing effort once an award is received, the following key elements must be taken into consideration:
• Total University Effort is the sum of all professional activity or effort for which an individual is compensated by the University.  Total University Effort is not based on a “standard” work week.  Total University Effort generally includes externally sponsored research activity, department research, teaching, clinical service, administrative duties, and proposal writing.  Activities outside of Total University Effort include personal consulting and other outside compensated professional work as described in the External Compensated Activity Policy, volunteer individual community or public service, and Veterans Administration Hospital compensated activities documented in a Memorandum of Understanding (MOU).
• Maximum Allowed Sponsored Project Effort: Most faculty are unable to devote 100% of their time to sponsored activities due to other responsibilities that include teaching, administrative work, patient care, competitive proposal writing, and service.  Accordingly, unless the circumstances of a particular faculty member demonstrably warrant otherwise, the total effort and salary of a faculty member should normally not be 100% supported by sponsored projects in a given effort period.  Such circumstances might include being on sabbatical, leave of absence, or having relief from teaching and other responsibilities.  Salary support for time spent on non-sponsored activities must not be charged to sponsored funding sources.
• Minimum Proposed Effort: All projects must show some level of activity (1% or more) by the faculty listed as PI/PD or key personnel unless specifically exempted by the sponsor (e.g., equipment grants). Such exemptions may include equipment and instrumentation grants, dissertation and training grants and limited purpose grants such as travel grants and conference support.
• Committed Cost-sharing of Effort: A cost associated with a sponsored project, identified in the proposal, but was not required or funded by the sponsor is considered voluntary committed cost-sharing. As a general practice, Boston University discourages the usage of committed cost sharing in sponsored project proposals.  This type of cost sharing must be accounted for through the creation of a cost sharing account once the award is received.
• Summer Effort/Salary for Faculty with nine-month academic appointments: Faculty compensated for 9-month academic appointments are permitted to expend up to an additional three months of summer effort and earn up to three months of additional salary for that effort, subject to sponsor policies and the approval of the Department Chair and School / College Dean.  If a faculty member has administrative or other non-research responsibilities (including vacations) during the summer period, they may be precluded from devoting 100% effort to sponsored projects and thus from requesting 3 months of salary from those sponsored projects.

9.9.2 Certifying Effort

Once an award is received and effort is devoted to the sponsored project, the University is responsible for providing a mechanism through which the effort devoted to the project is certified. In certifying effort, the following points must be considered:
• The percentage of an individual’s salary charged to a sponsored project cannot exceed the percentage of the individual’s effort that is expended on the project during an effort 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.
•Certification Eligibility:  BU certifies effort through the Personnel Activity Reporting (PAR) system. All faculty and non-faculty PIs must certify their own PARs.  Non-faculty personnel, such as professional staff and lab technicians may certify their own PARs or the PI or other responsible official(s) may certify the effort using suitable means of verification that the work was performed.  Student effort should be certified by the student’s supervisor or the PI.  Generally, a department research administrator will not have after-the-fact knowledge of an individual’s total work effort and should not certify the effort of research staff unless they have such written after-the-fact confirmation from an individual having direct knowledge and possessing suitable means of verification.

•Certification Timing:  Faculty, PIs and other individuals are responsible for completing Personnel Activity Reports within 60 calendar days from the time they are generated from the PAR system.

9.9.3 Activities Associated with Sponsored Project Effort

Identification of activities that can be supported by a sponsored project is critical to accurate effort reporting. Many work-related activities, although expected and paid for by the University, may not be appropriate for a sponsored project and do not further the mission of the project. Listed below are some of the activities that may or may not be appropriate for a sponsor to support. Examples of activities that are part of sponsored project effort:
• Effort devoted to conduct the research as identified in the proposal supported by, for example, NIH, NSF, DOD, foundations, or clinical trials.
• Writing a progress report for an existing award.
• Holding a research meeting with lab staff.
• Attending a scientific conference related to the research being conducted and held by an outside professional society or agency.
• Reading scientific journals to keep up-to-date with the latest advances in the field of research. Examples of activities that are not part of a sponsored project effort:
• Writing a new grant application.
• Mentoring a junior faculty member in the department (unless part of a sponsored project requirement).
• Attending departmental faculty meetings.
• Serving on the IRB/IACUC.
• Serving on an NIH Study Section.

9.9.4 Salary Reallocation & Recertification

Once certification of salary has been completed, only in rare circumstances will subsequent salary adjustments be permitted. If it is necessary to adjust the salary charges for a previously certified effort period, documentation including a detailed explanation of the need for the salary adjustment and subsequent recertification must be provided. This documentation must be approved by the Principal Investigator and be submitted to the Assistant Vice President for Post Award Financial Operations for approval. If approved, a revised and re-certified PAR and Salary Adjustment Request Form are then required. A salary reallocation that benefits the sponsor will always be approved.

9.9.5 Important Considerations

As sponsored projects start, expire, and overlap the line of communication must remain open between the PI/PD and the business office. The departmental administrative staff must know which individuals are expected to work on a new project and which awards or University accounts individuals will transfer to when an award expires. In addition, it is important for all parties to address effort commitments that will not be met or the need for a no cost extension to continue a project. Effort requirements could involve multiple parties, including the PI/PD, business office staff, OSP, and the sponsor.

For additional information regarding effort reporting at Boston University, please refer to the Sponsored Program Effort Certification Policy.