The emphasis thus far has been on preparing you to certify effort. Now we want to highlight some additional important issues.
In this module we explore the interplay between your effort commitment, your actual effort, and your salary charges during your work on a project. Six key principles are:
1. You are required to fulfill your effort commitment for each sponsored project budget period.
2. During a sponsored project budget period, your actual level of effort may vary.
3. Except for short term fluctuations, your salary charges must be consistent with your actual effort.
4. If you wish to change your commitment, you must always document the change and in some circumstances you must
obtain prior written approval from the Sponsor.
5. If you maintain your commitment level and your actual effort but reduce your salary charges to the grant, you must document this
increase in your cost shared effort.
6. If you receive an award from the sponsor and the budget is significantly less than you proposed, you must decide how you will
conduct the project an then confirm this with the sponsor-because the sponsor does not assume a proportional reduction of
This information is intended primarily for PIs, but the principles are important for all certifiers.
Effort variations within a sponsored project budget period
During the course of a sponsored project budget period, your level of effort may vary. This is acceptable, as long as you fulfill the overall commitment for the entire budget period.
Example: If you have committed 30% of your effort to a project during a calendar year budget period, one way you could fulfill that commitment is by expending:
- 10% effort during the first 4.5 months of the year
- 90% effort during the summer and
- 10% during the last 4.5 months
When does a variation in effort require an adjustment to the salary charges?
You must charge salary and certify your effort in a manner that is consistent with how you actually devote effort to the project. In the example above, where you work 10% in the first four ½ months; 90% during the summer and 10% in the last four ½ months – a perfectly acceptable way to fulfill the commitment – it would not be acceptable to:
- Charge salary at a constant 30% rate for the entire budget period, or
- Certify effort at a constant 30% rate for the each certification period
However, short-term fluctuations of two months or less are acceptable. This would be an effort deficit of not more than two months, provided that the catch-up occurs within a comparable period and it all evens out.
When does a change in effort require prior approval from the sponsor?
The rules depend on the type of change and your role on the project. First, the federal government defines a significant change in work activity as:
- A 25 percent (or greater) reduction in the level of committed effort
- An absence from the project of three months or more
- A withdrawal from the project
For a principal investigator/project director or key person as listed in the Grant Award
- A significant change in work activity requires prior approval in writing from the sponsor's Grants Officer. It is not okay to just communicate the change to your Program Officer.
- Any other change in your level of committed effort must be documented and communicated to the sponsor
Your committed effort is 40%, and you want to reduce it to 30%. The drop is 25 percent of your original effort commitment, so it requires prior written approval from the sponsor.
For a key person as identified in the proposal who is not listed in the Grant Award:
- Any change in your level of committed effort must be documented
For individuals who are not key personnel, commitments are not recognized and changes to effort levels need not be documented or communicated to the sponsor.
Changing the salary charged to a sponsored project
PIs generally have some flexibility in managing their sponsored project budgets, including their salary charges for project staff. However, this rebudgeting authority does not confer the right to:
- Make significant changes in work activity without prior approval from the sponsor, or
- Change effort commitments for key personnel without documenting the changes
Furthermore, if you reduce a person's salary charges without changing the effort commitment, that's an increase in cost sharing and should be documented as such.
Taken together, the rules regarding changes to salary charges and commitment levels are somewhat complex. They're summarized below, but you don't need to memorize them; the specifics are always available on the ORA Web site. For a significant change in work activity, documenting the change means communicating it to ORA after getting the sponsor's approval. For all other changes, documenting means maintaining a written or emailed record at the department level.
For an investigator or key person:
If you want to -- Then you must
- Reduce the salary charges without changing the effort commitment-- Document as cost sharing the effort for which the sponsor will not provide salary support
- Reduce both the salary charges and the effort commitment by less than 25% of the original commitment level-- Document the change to the commitment level
- Reduce both the salary charges and the effort commitment for a key person as listed in the grant by 25% or more of the original commitment level-- Obtain approval from the sponsor prior to the change and in writing, and document the change to the commitment level when approved
Reduce both the salary charges and the effort commitment for a key person listed in the proposal but not in the grant by 25% or more of the original commitment level-- Document the change to the commitment level
For a project staff member who is not an investigator or key person:
If you want to – Then you must
- Reduce the salary charges without changing the effort -- Document as cost sharing the effort for which the sponsor will not provide salary support
- Reduce the salary charges and the effort by commensurate amounts -- No documentation, notification, or approval is required
When the awarded budget is less than proposed
If you receive an award from a sponsor and the budget is less than you proposed, you cannot assume that your effort commitments are automatically reduced by a proportionate amount. You may need to confirm the effort commitments and the arrangements for salary support with the sponsor.
You have three options:
1. Reduce the effort commitments in proportion to the budget reduction. With a budget reduction of 25% or more, you must request
approval from the sponsor for this option. A reduction of that magnitude (10% or greater on an NSF award) generally indicates
a project scope reduction, so a proportionate reduction of effort commitments would be appropriate.
2. Keep the proposed effort commitment and salary arrangements, and reduce expenditures in non-salary budget categories.
3. Keep the proposed effort commitments but reduce the salary charges. This increases the university's voluntary cost sharing for
the project, and must be explicitly approved in accordance with your college or school's policies on cost sharing.
The terms and conditions of your award apply throughout the project period, including a no-cost extension period. This includes the PI's effort commitment. At the same time, federal agencies realize that PI effort may be reduced during no-cost extensions as the project is winding down, or when data analysis requires additional time.
While this is not considered a change in scope, it is in the best interests of the institution and the PI to notify the sponsor of this decrease in effort to avoid discrepancies with current and pending support statements, effort certification, or issues of research overlap.