[October 15, 2020] Effort Commitment Guidance for Federal Proposals
Effective January 5, 2001 through a Presidential Review Directive and clarification memo M-01-06 issued by the Office of Management and Budget (OMB), it is expected that “most Federally-funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the Federal government. This effort can be provided at any time within the fiscal year (summer months, academic year, or both).” The clarification memo also states that, “...Some types of research programs...do not require committed faculty effort, paid or unpaid by the Federal government...”
Further, the National Institutes of Health (NIH) Grants Policy Statement notes that “zero percent” effort or “as needed effort” is not an acceptable level of involvement for key personnel. Therefore, in preparing proposals and in allocating effort after award, all PIs and key personnel (not including Other Significant Contributors) must include some level of committed effort on most sponsored research activities. Some exclusions apply (see EXCLUSIONS below). Any programs that do not cover key personnel salary expenses as a matter of policy do not qualify as an exclusion (instead, effort must be cost shared). Any effort devoted by these individuals that is above the committed effort amount is considered uncommitted effort. Other contributing personnel must be included in the proposal reflecting their effort contributions to the project.
PIs must quantify effort commitments (e.g., a percentage of time, dollar amount of salary, number of months, etc.) in the proposal. These commitments are paid from (1) the sponsor and/or (2) other, non-federal sources. The effort commitments must be fulfilled within each year of the award.
The minimum amount of effort committed to a specific sponsored research activity should be no less than 1 percent of the key personnel’s university effort. Beyond this minimum, the specific amount of effort committed to a particular grant should be based on the PI’s estimate of the effort necessary to meet the technical goals and outcomes of the project. If you have questions, about minimum levels of effort, or converting hours to percent efforts, please contact your Sponsored Programs Officer. In addition, NIH institutes may have minimum effort requirements for some grant mechanisms, see details in the National Cancer Institute Notice.
EXCLUSIONS
Some federal and federal flow-through sponsored programs do not require a minimum level of committed effort by PIs and key personnel and therefore are not subject to this policy. The following are excluded from the requirements set forth above.
NOTE: This list is not all-inclusive. Contact your Sponsored Programs Officer with questions.
• Equipment and instrumentation grants
• Mentor effort on doctoral dissertation, fellowship, scholarship awards, training grants, and resident research experiences
• Specific purpose awards such as travel grants, outreach programs, workshops, and conference support grants
• National Science Foundation (NSF) Research Experiences for Undergraduates (REU).
• NIH supplements (For the PI, committed effort must be present on the parent grant supporting the supplement.)
• NIH Other Significant Contributors as cited in the agency’s SF424 Application Guide
• Non-federally funded clinical research/trial/treatment – On a case-by-case basis, where PI oversight related to research is expected to be very minimal, it may be appropriate to budget less than one-percent effort.
[September 17, 2020] What is the NIH viewing window for electronic applications? Applicants who submit at least two days in advance of the deadline have two business days to view their assembled application in the eRA Commons. This viewing window enables applicants to verify that their application is viewable correctly and, if not, to work with an institutional Signing Official to reject, modify, and resubmit it. However, any modifications or corrections must be completed PRIOR to the due date. Applicants are strongly advised to submit early and to allow enough time for an adequate review in order to ensure the successful submission of their applications. In general, OSPA will only reject and resubmit applications for reasons such as missing documents, illegible figures, and validation warnings. More>> [Faculty, Postdocs and Resadmin 9/17/2020]
[August 20, 2020] What is Responsible Conduct of Research (RCR)? Responsible conduct of research is defined by NIH and others as the practice of scientific investigation with integrity (NOT-OD-10-019). RCR involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research. More>> [Faculty, Postdocs and Resadmin 8/20/2020]
[August 20, 2020] Who is required to take Responsible Conduct of Research (RCR) training on campus? The current institutional requirement is that all pre- and post-doctoral appointees on NIH funded NRSA programs must attend a Responsible Conduct of Research Course in the first year of their appointment (Tri-Institutional RCR Course). In addition, all first year Graduate Fellows and third year Biomedical Fellows must attend, so that they are trained in ethical considerations from the outset of their graduate education. Additionally, The NSF requires institutions to verify that undergraduate students, graduate students, and post-doctoral researchers supported by NSF to conduct research have received training in the responsible and ethical conduct of research (RCR). The Dean's Office oversees the RCR training requirement on campus. More>> [Faculty, Postdocs and Resadmin 8/20/2020]
[Febuary 27, 2020] What information should be included in the Project Summary/Abstract and Project Narrative sections of my NIH application? The Project Summary/Abstract should outline the broad, long-term goals and specific aims of the project and its biomedical relevance, as well as describe the research design and methods for achieving the project objectives. This section is limited to 30 lines of text; figures should not be included. Investigators should describe the benefits of their proposed research to public health in their Project Narrative section of their NIH application. This section should be succinct – no more than 2-3 sentences long - and in plain language. If the application is funded, both sections will be viewable to the public in the NIH RePORTER, and any proprietary or confidential information should be excluded. More>> [Faculty, Postdocs and Resadmin 2/27/2020]
[January 23, 2020] Record Retention Requirements Most sponsored projects have legal requirements as to how long project records must be retained. These guidelines also recognize the substantial physical and fiscal resources required to retain technical, clinical, financial and other records (contact your Sponsored Programs Officer for assistance).
Awarded Applications:
• Federal awards - Retain records for 3 years after submission of the final fiscal status report (annual or, if annual is not required, competitive segment) or after final payment under a Federal contract. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken. Record retention under Federal grants is governed by 2 CFR 200. Record retention under Federal contracts is governed by the Federal Acquisition Regulation, specifically FAR 52.215-2.
• State and other governmental awards – A number of these awards require that records be retained for six (6) years. It is recommended that all records for projects funded under State/governmental awards (MOUs, grants, agreements) be retained for 6 years.
• Other awards - If the sponsor or award document does not specify a specific time period to retain project records, follow the Federal contract requirement (retain for 3 years after final payment under the award).
[Faculty, Postdocs and Resadmin 1/28/2020]
