S. Proposing, Managing, and Certifying Effort for Employees Engaged in Externally Sponsored Programs
1.1 Administration. Services that benefit common or joint university or department activities in organized research units, academic departments or programs, and in the offices of the deans, vice presidents, provost, and president. For purposes of this policy, "Administration" also includes proposal preparation for competing renewal and new applications.
1.2 Departmental/University Research. Research, development, scholarly, and creative activities conducted under University of New Hampshire (UNH) auspices but not funded by an externally-sponsored project.
1.3 Effort. Time spent by a UNH employee on any USNH activity, including Sponsored Programs.
1.3.1 Committed Effort. Total projected amount of time the UNH employee has agreed to work on a sponsored project or other USNH activity.
1.3.2 Cost Shared (Contributed) Effort. Percentage of committed Effort not funded by the sponsor, i.e., to be paid for and contributed as cost sharing by UNH.
126.96.36.199 Mandatory Cost Sharing of Effort. Funding that, either due to award terms/ conditions or by federal statute, requires UNH to contribute personnel costs and corresponding Effort to the project as a condition of receiving the award.
188.8.131.52 Voluntary Committed Cost Sharing of Effort. Personnel costs and corresponding Effort associated with a sponsored project, which were identified in the proposal, but not required or funded by the sponsor.
184.108.40.206 Voluntary Uncommitted Cost Sharing of Effort. Personnel costs and corresponding Effort associated with a sponsored project and not funded by the sponsor, which were not committed in the proposal or in any other communication to the sponsor.
1.3.3 De minimis Effort. Infrequent, irregular activity that normally would be considered "so small" that it cannot (and should not) be accounted for. Activities can be considered de minimis in amount when, in the aggregate, they represent less than one percent of the individual's Total University Effort. (See UNH VIII.S.1.3.4.)
1.3.4 Total University Effort (TUE)
All activities for which the employee is compensated with USNH-administered funds for performing Regular Duties and for work for which the employee receives Additional Pay. (See UNH V.F.1.1.13 for definition of Regular Duties and UNH V.F.7 for the Additional Pay policy.) Types of Additional Pay unrelated to Effort (e.g., Employee Transition Allowance or monetary awards for recognition) are excluded from consideration for TUE. TUE is 100% regardless of FTE %.
TUE includes all USNH Effort-based activities regardless of when during the daytime, evening, weekend, or year, or where (e.g., on campus, at home, while traveling) the activities take place. TUE is not based on a 40-hour work week, but rather on the total USNH hours the employee spends on the combination of Regular Duties and Effort expended for Additional Pay. For example, if a person averages 60 hours per week on USNH activities and spends an average of 15 of the 60 hours per week on a Sponsored Program, that person is spending 25% Effort on the Sponsored Program and 75% on other duties.
See UNH VIII.S.3.8 – "Table on Total University Effort" – for examples of activities allowable as direct charges on Sponsored Programs.
1.4 Effort Certification. Process by which the UNH Principal Investigator (PI), Project Director (PD), other knowledgeable UNH employee, or the employee him/herself affirms that the percentages of received pay displayed on the Effort Report are a reasonable reflection of the percentages of Effort that the paid individual expended on each Sponsored Program and other work activities.
1.5 Effort Report. Listing of USNH accounts from which the UNH employee has been paid for Effort expended during a specified period; used for Effort Certification.
1.6 Instruction. Preparation, evaluation, and delivery of the university’s teaching and training activities, regardless of whether offered on a credit or non-credit basis. Also includes Instruction-related activities, such as thesis advice, student mentoring, and similar activities. Student mentoring directly related to a faculty member’s sponsored research is considered a research activity that may be allocated to the Sponsored Program.
1.7 Service. Membership in a standing committee (e.g., admissions committee, governance body, Human Subjects Review Board) or an ad hoc committee such as a search committee or task force. Service may qualify as de minimis Effort, depending on the extent of the individual’s involvement. (See UNH VIII.S.1.3.3 above.)
1.8 Sponsored Program. Project funded by an award from a grant, contract, or cooperative agreement under which UNH agrees to perform a certain scope of work, according to specific terms and conditions, and which requires detailed financial accountability and compliance with sponsor terms and conditions.
1.9 Sponsor Salary Cap
In some cases, sponsors impose limitations on the amount of Institutional Base Salary (IBS) or Rate (IBR) that may be used as the basis for charging salary to their projects. (See UNH Regular Pay policy at V.F.1.1.9 and V.F.1.1.10 for IBR and IBS definitions.) This is known as the "Sponsor Salary Cap." This does not affect the employee’s actual pay, just the source.
2. Scope, Applicability, and Purpose
2.1 This policy sets forth requirements for proposing, managing, and certifying Effort on externally-Sponsored Program awards administered by UNH. The policy applies to all employees whose pay is charged to UNH-administered sponsored projects, in whole or in part, and to all UNH employees who have committed Effort to a sponsor but are not receiving salary support from the sponsor, also known as cost sharing. The policy applies regardless of whether or not the sponsor is Federal.
2.2 In requesting external funding for projects and programs, UNH must ensure that the proposed commitments of Effort are reasonable and conform to UNH’s and the sponsor’s expectations of the employees involved. If external funding is awarded, UNH must assure the sponsor that the proposed Effort will be effectively managed within the parameters of the sponsor’s requirements and UNH policy.
2.3 In addition to complying with the sponsor's expectations and requirements for allowable and appropriate charges to Sponsored Programs for Effort expended, UNH must comply with the Federal Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions, specifically, Section J.10, Compensation for Personal Services.
3.1 Proposals: Proposing Effort Commitments and Requesting Related Salary/Wage Support on Sponsored Programs
220.127.116.11 In preparing proposals, PIs and PDs must propose some level of activity (1% or the minimum required by the program) unless specifically exempted by the sponsor. PIs/PDs are expected by UNH to provide reasonable estimates of the percentage of Effort for themselves and all other key personnel necessary to carry out the proposed project. Proposed levels of Effort should be consistent with the actual Effort each employee is expected to expend on the project during the relevant project period(s). The amount of salary support requested normally should be determined by multiplying the proposed level of Effort percent by the employee's IBS or IBR. Salary support that is not requested normally should be stated as cost shared (contributed) Effort. (See UNH VIII.S.3.1.2 below.)
18.104.22.168 For proposal purposes, the proposed level of Effort must be expressed in accordance with sponsor requirements. Some sponsors require that level of Effort be proposed in terms of person months (e.g., three person months of a 12-month appointment), whereas others expect the proposed level of Effort to be expressed in percentage terms (e.g., 25% of TUE for the proposed project period.) In no event should the requested salary support exceed the amount determined by multiplying the proposed level of Effort percent by the IBS/IBR. (See UNH V.F.1.1.9 and 1.1.10 for IBS and IBR definitions.)
22.214.171.124 Regardless of the amount of Effort proposed, the total amount of Effort committed in the awarded proposal must be provided and ultimately certified.
3.1.2 Cost Shared (Contributed) Effort (See also UNH VIII.S.1.3.2.)
126.96.36.199 If the sponsor requires Mandatory Cost Sharing for the program, this requirement can be met through cost sharing of PI/PD/key personnel Effort, with approval prior to proposal submission by the Responsibility Center unit head (normally the dean or institute director) and the UNH sponsored programs administration office.
188.8.131.52 UNH typically does not cost share/ contribute Effort on a voluntary basis (see UNH VIII.M, Cost Sharing on Externally Sponsored Programs). Approval for Voluntary Committed Cost Sharing of Effort must be obtained prior to proposal submission from the Responsibility Center unit head and the UNH sponsored programs administration office. This type of cost sharing is agreed to as part of the award and is required to be documented, tracked, and reported. Voluntary Uncommitted Cost Sharing of Effort is not required to be documented, tracked, or reported.
3.1.3 Sponsor Salary Caps (See also UNH VIII.S.1.9.)
184.108.40.206 Where Sponsor Salary Cap limitations apply, the requested salary support is determined by multiplying the proposed level of Effort percent by the maximum IBS allowed by the sponsor.
Such limitations result in an automatic situation of cost shared (contributed) Effort, where the total Effort is split between Effort allowed to be charged to the sponsor and Effort funded by UNH. There may be other circumstances in which UNH may elect to request salary support at a lesser amount than the salary that could be requested based on proposed level of Effort.
3.1.4 Maximum Proposed Salary
220.127.116.11 Normally, a PI/PD may not request in a single proposal to receive externally-sponsored salary support for more than 95% of his/her IBS. Faculty with 9-month appointments normally may not request in a single proposal to receive externally-sponsored summer salary support for a full 3 months. (See also UNH V.F.7.1.35, V.F.7.3.5, and UNH VIII.S.3.3 for additional information on Summer Pay and Effort.)
18.104.22.168 It is understood that the sum of active + proposed percentage commitments for a given period may exceed 100%, because proposals may not result in awards. However, to the extent that a proposal results in an award, reductions must be made to existing commitments (and the sponsors notified when required and/or appropriate) to ensure that the total Effort percentage committed to Sponsored Programs does not exceed 95% during the regular appointment period (or 100% during the Summer Period for academic-year faculty) for each UNH employee who will receive pay from the award. ("Summer Period" is defined as the approximately 13 weeks between academic years.)
22.214.171.124 In rare situations, Additional Pay for Effort beyond the employee’s Regular Duties (see UNH V.F.1.1.13 for definition of Regular Duties) may be proposed to the sponsor. (See UNH V.F.7 for Additional Pay types and policy for requesting and obtaining UNH approval.)
3.2 Awards: Establishing Salaries on Sponsored Project Award Accounts
3.2.1 Sponsors generally consider estimates of Effort (and corresponding salary requests) in proposals to be commitments if such proposals are awarded. If an award is accepted by UNH, the PI/PD/key personnel are committed to provide this level of Effort over the award budget period unless sponsor policies permit otherwise. As a recipient of sponsored funds, UNH must assure sponsors that the Effort expended on the projects is at least commensurate with the salaries charged to those projects. In addition, sponsors require assurance that any Effort committed to a project, even Effort not compensated by the sponsor, is provided. PIs/PDs are responsible for ensuring that all Effort commitments are met for the project and ultimately certified.
3.2.2 Unless specifically required by a federal sponsor to follow a different federally-approved acceptable method for payroll distribution, UNH adheres to the Plan-Confirmation method. (See UNH VIII.S.3.5.5 and UNH VIII.S.3.5.6 for exceptions.) Under Plan-Confirmation, the distribution of salaries and wages of professorial and professional staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity, periodically updated to reflect any significant changes in work distribution when those occur. Salary/labor distribution consistent with committed Effort should begin on sponsored project award accounts (and cost sharing accounts, if applicable) concurrently with actual project Effort. It is the PI's/PD's responsibility to be aware of committed Effort for himself/herself and all project staff, and to promptly communicate via a written work plan with his/her UNH Business Service Center (BSC) to assign salary charges to the award and adjust charges to other USNH accounts as appropriate.
3.2.3 Maximum Allowed Regular Pay From Externally-Sponsored Programs
An employee's pay may not be charged directly to an externally-Sponsored Program for activities that are not identified in that specific program. Pay for Administration, Instruction, Service, clinical activity, institutional governance, and new or competitive proposal preparation must not be charged directly to externally-Sponsored Programs unless the activities are specifically approved activities of those Sponsored Programs. With the proviso that unrelated and unallowable activities may not be charged, a maximum of 95% of a UNH employee's Regular Pay during each fiscal year may be charged to Sponsored Programs. With written approval from the UNH Senior Vice Provost for Research (SVPR), exceptions can be made up to 100% if the employee is working exclusively on the Sponsored Program(s). (See UNH VIIII.S.3.8, Table on Total University Effort, for examples of activities allowable for directly charging Sponsored Programs.)
Some sponsors may impose a cap on the amount they will reimburse for individual salaries in awards. For example, the National Institutes of Health will not reimburse at an annual rate that exceeds the cap it publishes each year. Also, the National Science Foundation normally limits compensation it will provide to two months during the institution's fiscal year. UNH strictly observes all sponsor salary reimbursement limitations.
126.96.36.199 Academic Year Faculty During the Regular Appointment Period
Normally, faculty members have responsibilities during the academic year that preclude them from devoting 100% of their time to externally-sponsored activities. Deans and department chairs or their designees, and faculty should review proposed sponsored activity to assure that, if other activities required of the faculty member reduce the available Effort to devote to sponsored activities, payroll distribution adjustments are made consistent with sponsor terms and conditions.
188.8.131.52 Fiscal Year Faculty and Staff during the Regular Appointment Period
Fiscal year faculty and full-time staff members with teaching, research, Service, and/or administrative responsibilities normally are precluded from devoting 100% of their time to and receiving 100% of their UNH pay from USNH-administered externally-Sponsored Programs.
Some fiscal year full-time staff members in certain classifications (e.g., research scientists and research technicians) are expected to devote 100% time to Sponsored Programs; these positions are given categorical approval by the SVPR to charge 100% of their pay to Sponsored Programs. However, if these individuals wish to engage in other UNH activities, they must receive their supervisor's and SVPR approval in advance to do so, and reduce the percentage charged to Sponsored Programs accordingly for the time period approved for the other activities.
184.108.40.206 Adjunct Appointees
The employee's related pay may be charged directly to USNH-administered externally-Sponsored Programs in accordance with UNH VIII.S.3.2.3 above.
3.3 Summer Effort/Salary for Faculty with 9-Month Academic Appointments
For purposes of this policy, the definition of a Summer Period (see UNH V.F.1.1.16) workweek is consistent with the definition of an Academic Year workweek (see prevailing Collective Bargaining Agreement). It is expected that faculty engaging in externally-sponsored projects during the Summer Period will not allow other activities (e.g., teaching, proposal writing) performed during the Summer Period to interfere with or reduce the faculty member's ability to expend summer Effort on externally-sponsored projects, as that Effort is committed to sponsors and for which he/she is earning summer salary. If the Effort associated with any such other activities could not be conducted reasonably along with externally-sponsored commitments, the faculty member has the obligation to adjust, and likely decrease, summer commitments and salary on externally-sponsored projects.
A request for summer salary indicates a commitment to put forth the comparable Effort on the particular project during the Summer Period. Effort expended during the Academic Year does not satisfy a commitment related to receipt of summer salary. While personal time off may be taken during the Summer Period, it is not appropriate to concentrate significant time off during a period for which the faculty member is receiving 3 months Summer Period salary.
3.4 Post-Award: Revising and Monitoring Effort and/or Salary Commitments on Sponsored Project Awards
3.4.1 With each new award received, changes in other USNH commitments, and/or other changes in activity that could impact the level of effort proposed/awarded for sponsored projects, the PI/PD is responsible for reviewing the Effort commitments for each activity to ensure there is sufficient time available to meet all obligations. PIs/PDs must ensure that with each new award or additional assignment (such as for Service on a UNH committee), he/she adjusts the percentage of Effort and associated compensation plan for each activity accordingly. It is the PI's/PD's responsibility to communicate promptly via a written revised work plan with his/her Business Service Center (BSC) to assign labor distributions to the new awards/activities and adjust for future charges to other UNH accounts as appropriate.
220.127.116.11 Retroactive salary/labor adjustments to Sponsored Programs are discouraged. If an error has occurred, the PI/PD must provide written documentation to the BSC to explain the reason for the error. Except for UNH-mandated adjustments such as retroactive salary increases, no retroactive salary/labor adjustments greater than 90 days after the original transaction posting may be made to Sponsored Programs without prior approval from the BSC and the sponsored programs administration office. All adjustments are subject to after-the-fact review and possible disallowance by the latter office.
3.4.2 When sponsor approval is required for reductions in Effort on awarded projects, PIs/PDs must obtain UNH and sponsor approval prior to reducing their Effort. If an Effort reduction is indicated for a sponsored project award, the salary charged to the sponsor must be reduced commensurate with the Effort reduction.
3.4.3 The PI/PD must communicate significant changes in level of Sponsored Programs effort to his/her BSC such that salary distribution adjustments are made on a timely basis.
3.4.4 It is recommended that PIs/PDs monitor salary/labor charges to their Sponsored Programs on a monthly basis, but no less frequently than quarterly.
3.5 Certifying Effort
3.5.1 Each UNH employee (or other responsible person with specific knowledge of the employee's Effort) must certify his/her TUE if all or part of the related compensation was funded by UNH Sponsored Programs during the period covered by the Effort Certification.
3.5.2 If the individual certifying the Effort is other than the employee, the certifier must use "suitable means of verification" that the work was performed and that the associated pay was reasonable in relation to the Effort. It is the PI's/PD's responsibility to ensure that appropriate records (e.g., calendars, teaching schedules, lab log books) are up-to-date and available for review or audit to substantiate that the work was performed. Such records may be considered suitable means of verification. Other means of verification might include e-mail messages attesting to Effort devoted, based on firsthand knowledge. Oral verification alone will not suffice.
3.5.3 If the percentages of actual TUE differ from the percentages of actual pay on Sponsored Programs by more than 5% for the certification period, the PI/PD must promptly communicate in writing to the BSC the details and explanation such that corrections can be made to the payroll system. Differences of 5% or less do not require payroll system adjustments unless the associated costs are unallowable. An example of an unallowable cost is time spent on competitive proposal writing.
3.5.4 De minimis activity (less than 1% of TUE) devoted to non-sponsored university activities is not required to be identified on the Effort Report, but may be allocated to Sponsored Programs and non-sponsored activities consistently and equitably. Examples of de minimis activities may include attending departmental meetings, completing performance reviews for supervisees, and enrolling in employee benefit programs. Proposal writing for new and competitive renewal projects, and well-defined, regular Administration (see UNH VIII.S.1.1) and Service (see UNH VIII.S.1.7) activities cannot be considered "small", therefore must not be treated as de minimis.
3.5.5 An Effort Certification must be completed annually by or for each salaried employee who received pay from one or more UNH Sponsored Programs under the Plan-Confirmation method during the Effort Certification period. Effort Certifications are to be provided to the UNH sponsored programs administration office no later than September 30 each year for the preceding UNH fiscal year reporting period. UNH employees whose salaries are charged to sponsors requiring a different certification method, such as After-the-Fact Activity Reporting, generally certify their Effort monthly.
3.5.6 Hourly-based employees either submit bi-weekly timesheets or use Web Time Entry (WTE) as part of the UNH bi-weekly payroll process. When certified by the employee and approved by his/her supervisor, approved timesheets or WTEs reflecting TUE may meet the requirements of After-the-Fact Effort Certification for hourly-based employees receiving wages from UNH Sponsored Programs. The BSC is responsible for retaining and maintaining for audit purposes the approved records.
3.5.7 Because it is expected that the PI/PD will promptly initiate future labor distributions and correct errors to prior salary/labor charges to his/her Sponsored Programs, instances of re-certification of Effort after the original certification is filed should be rare. Approval by the UNH SVPR is required in order for UNH to accept a correction of a previously-filed Effort Certification.
3.6.1 Each UNH employee who receives pay from at least one UNH externally-Sponsored Program, a cost sharing account related to a Sponsored Program, and/or from UNH's federal appropriations must complete the Effort Certification training made available by UNH. Training must be completed within 30 days after the pay from the external funds commences and once every three years thereafter. Exceptions to this training requirement include student and non-permanent employees who receive one-time payments.
3.6.2 Each PI/PD must complete the UNH on-line Effort Certification training module even if s/he does not receive pay but supervises employees who are paid by the PI's/PD's Sponsored Program.
3.6.3 The PI's/PD's BSC and local business/administrative staff supporting UNH Sponsored Programs are encouraged to complete this training.
3.6.4 It is the PI's/PD's responsibility to ensure that the employees to be paid (from the funds for which he/she is the PI/PD) successfully complete the on-line training module.
3.7 Consequences of Non-Compliance
3.7.1 If a PI/PD does not complete the specified training, the PI's/PD's next award will not be accepted by UNH until such time as s/he successfully completes the training.
3.7.2 If an employee fails to return his/her Effort Certification within the required period, no further proposals will be submitted nor awards accepted by UNH for the employee/PI/PD until such time as the certification is completed and submitted to the sponsored programs administration office.
3.7.3 Sponsored Programs funds expended for employees who violate this policy may be disallowed by the sponsor and/or UNH. In such cases, the PI/PD and his/her college/school/department must provide unrestricted UNH funds to reimburse the sponsor.
3.7.4 Other violations of this policy will be addressed under the USNH Employee Code of Ethics and other policies as appropriate.
3.8 Total University Effort Table
Total University Effort Table
(Activities considered part of TUE and whether those activities are chargeable to sponsored programs)
Activity Included in Total University Effort? Chargeable to UNH Sponsored Program? ADMINISTRATION College/school/dept./research center leadership (e.g., dean/chair/director) Yes No CLINICAL ACTIVITY Clinical services provided in a facility unaffiliated with UNH and for which no UNH compensation is received No No Clinical services provided in a UNH facility and compensated through UNH Yes If directly identified in the sponsored program DEPARTMENTAL/UNIVERSITY RESEARCH/SCHOLARSHIP Research or other scholarly activity conducted without external sponsorship Yes No INSTRUCTION Teaching a course or seminar at USNH Yes If directly identified in the sponsored program Working with students or maintaining office hours Yes If directly identified in the sponsored program Guest lecturing at a non-USNH institution Yes, unless compensated by that institution No, unless it is about work for the specific UNH sponsored program SERVICE OUTSIDE USNH Consulting No, unless compensated through USNH No, unless directly identified in the sponsored program Journal peer review No No Funding agency proposal review No, unless UNH reimburses associated travel and expenses No Professional society participation No, unless UNH reimburses associated travel and expenses No, unless directly identified in the sponsored program SERVICE TO USNH Committee member or chair
(e.g., PSU search, dept., tenure, UNH IRB)
Yes No SPONSORED PROGRAMS ACTIVITY Research or service pursuant to a UNH sponsored program award Yes Yes, if the sponsor agreed to fund the effort
No, if the sponsor requires the effort but has not agreed to fund it (mandatory cost sharing)
No, if the researcher volunteered the effort but the sponsor has not agreed to fund the effort (voluntary cost sharing)
Writing competitive funding proposals Yes No Writing continued funding applications and progress reports Yes Yes, when directly identified to the specific sponsored program Writing scholarly articles Yes No, unless directly identified in the sponsored program