Idle Time Project FAQs
The Office of Management & Budget (OMB) released guidance to federal agencies on March 19th allowing a number of flexibilities for the research community including the allocation of idle time to research awards. University Leadership sent a memo to all faculty noting that per OMB memo M-20-26, idle time on grants can continue to be charged on BU sponsored awards through September 30, 2020.
Moving forward, faculty who utilize the flexibilities provided by the OMB memo and their funding agency must document any additional funding sources available to them and provide a reason why these sources are not being used to offset costs. Sponsored Programs and Post Award Financial Operations have created a simple template that can be used to produce this required documentation. Please note, this is only necessary for research taking advantage of this flexibility after June 18, 2020.
These FAQs address the documentation needs regarding idle time that is allocated to an award. The tracking sheet for indicating idle time can be found here: https://bushare.sharepoint.com/sites/BU-COVID-Research-Time
Internal
Q: Why are we doing this?
PAFO is requesting information from PIs about time tracking of idle time for compliance purposes. In addition, Boston University is audited annually under Uniform Guidance and we believe this documentation will be requested as part of that audit.
Q: How do I know if I have idle time?
Idle time on research is defined as time that you were unable to work on your research due to disruptions from COVID-19. A common example of this is the inability to continue work due to a lab shutdown. That being said, as with every aspect of our lives over the past two months, most research projects have experienced some amount of disruption. For example, the particular activities conducted during the months of March and April were likely different than those originally planned (e.g. changes in activity due to cancelled travel or delayed recruitment). Additionally, even in the absence of a pandemic, there is always some amount of month-to-month variability during any project period. This type/degree of disruption is much different than the “Idle time” that PAFO is requesting. If you and your research team were able to continue progress on your award and the time spent on the project was generally consistent with the planned salary allocation within the bounds of normal month-to-month variability, then it is appropriate for you to report the time as “Active.”
Q: Do I need to track weekly employees who submit time through the SAP system?
For Non-Exempt Hourly staff you do not need to indicate their idle time on the tracking system if they are actively using the “Department Closure” code (2033) when submitting their weekly time. All weekly employees should be using the “Department Closure” code and will be expected to do so from May 1 onwards.
Q: How is this different than effort reporting? Do we still need to do effort reporting every 6 months?
Effort reporting is a separate and distinct process that provides an indication of the level of effort on a research award. This exercise is evaluating the impact of COVID-19 on our ability to execute research and does not replace effort reporting. Idle time indications should be used when significant disruption is incurred while effort reporting is confirming the effort on an award over a 6 month period.
Q: Is the expectation that PI’s or grant managers reach out to project staff for their effort estimates?
No. We realize that there will be a level of disruption but as this is not a certification of effort. Detailed effort estimates should be reserved for the effort reporting process (i.e. PARs). This exercise is just to track idle time and determine the level of COVID disruption. We expect that most researchers have been able to continue research in some form and can simply list “Active” where work is continuing.
Q: Once this information is reported, will grants managers be informed to adjust payroll accordingly?
As PAFO and Sponsored Programs gather allowability of idle time information from Sponsors, departments will be notified directly if salary has to be moved; until then, no salary should be moved outside of the normal effort reporting process. If a PI hears from a Sponsor that idle time is not allowed, please let Gretchen Hartigan (hartigan@bu.edu) and Diane Baldwin (dbaldwin@bu.edu) know.
Q: Is it allowable to anticipate that any reduced effort in March/April can be recovered by increased effort in May/June?
If reduced effort in March and April will essentially be recovered via increased effort in May and June, then for the purpose of this reporting exercise, the work did not experience a COVID-related disruption and the allocation should be reflected as “Active.” “Idle” time indicators should only be used to show COVID-related disruptions that will not be recovered in the coming months.
Q: Should COVID-related sick time or vacation time be reflected?
COVID related sick time or vacation time is just like regular sick time or vacation time and should be listed as Active in this exercise.
Q: Will this reporting be required or updated for May and (if necessary) subsequent months?
Yes. As the OMB guidance is applicable this exercise will be required.
Sponsors
Q: Should PI’s now communicate with sponsors who may require prior approval or those not allowing pay for idle or reduced time? Will Sponsored Programs contact sponsors about idle time? We do not recommend PI’s proactively reaching out to sponsors without first coordinating with their SP RA to determine if prior approval notification is required or if idle or reduced time is covered by OMB flexibilities. If PI’s are receiving notification from their sponsors, please forward that correspondence to Gretchen Hartigan (hartigan@bu.edu) or Diane Baldwin (dbaldwin@bu.edu) so they can coordinate the response. Once the data collection on the idle time has been completed, SP and PAFO will be reviewing that to determine which sponsors will need to be contacted about idle time approval.
Q: Will departments be required to confirm Sharepoint info is consistent with previously submitted RPPR’s, progress reports/invoicing, or match with PO/sponsor expectations?
No, not for previously submitted RPPRs or progress reports. However, the information should be consistent with RPPRs and progress reports moving forward. Allowable idle effort charged must be reported in sponsor reports as well as the COVID-19 impact or disruption on projects. It should be noted that the SharePoint changes will not be fed back into Payroll.
Q: If effort is reduced in March and April, can we assure sponsors that during reboot/ramp-up effort will increase similarly (May onward) to meet project annual effort commitment?
Yes, but if your report idle time and the Sponsor does not allow idle time, you will still have to remove any March/April idle time from the grant. As described above, if reduced effort in March and April will essentially be recovered via increased effort in May and June, then for the purpose of this reporting exercise, we can feel comfortable considering this time as “Active.” If you are changing effort for the period that should go through the normal request process for salary allocation changes.
Q: Will this information be required to be reported to us by our subrecipients? Should (Prime) PI’s be contacting their collaborators?
We are assessing what a process/communication to our subrecipients needs to look like. Subrecipients should continue to submit progress reports to the BU PI as required in the sub agreements issued by BU and we expect any COVID impacts or disruptions should be noted there so that the BU PI may incorporate this information in the overall progress report to the sponsor. BU PIs should be in regular communications with their subrecipient collaborators as to the progress of the project and we do not suggest any specific outreach to their collaborators at subrecipient institutions, but if they receive information, please share with their sponsored programs RA.