Research Effort Policy

RESEARCH EFFORT POLICY
Effective: December 1, 2023

Responsible Office: UFCVM Office for Research and Graduate Studies

Reason for Policy

The University of Florida (UF) must adhere to all federal regulations applicable to sponsored research, including research effort reporting (https://research.ufl.edu/dsp/award-management/fiscal-management/effort-reporting.html). Federal regulations require that each institution maintain internal controls to ensure that renumeration paid under sponsored programs are reasonable, conform to established written policies, and provide accurate documentation of expenses (2 CFR200, “Compensation-Personal Services”).
For this purpose, UF defines faculty effort by mission type and uses an effort reporting system to distribute salary charges among these activities. Since effort reports are the source documents to support salary charges to sponsored projects, the data must be based on reasonable estimates of the actual effort expended on each sponsored project vs non-sponsored or university funded accounts. To align with UF policy, the College of Veterinary Medicine (CVM) has implemented an internal research effort policy to guide faculty and ensure compliance.

Policy Statement
CVM is committed to accurately capturing research effort and timely effort reporting. In preparing applications for sponsored funding, Principal Investigators (PIs) are expected to provide reasonable estimates of the effort necessary for themselves and their key personnel carrying out the project. While salary charges are initially estimated based upon the planned workload of faculty and others in the proposed budget, the actual effort of each individual must be captured in the subsequent effort report to be completed by the PI with charges modified as necessary to reflect any variances between the estimated and actual effort. For details on the process of proposing and certifying research effort, please review the following sections.
Faculty Research Effort Faculty effort is defined as the compensated time faculty members spend on research, extension, teaching, clinical activity, and administration or service, as determined using a standardized process across the college. By definition, the individual’s total effort must equal 100% with the individual activities indicated as a percentage of total activity. As required by UF policy, a faculty member’s time and effort on grants must accurately reflect the commitment to the grant and must seek salary support commensurate with the percent effort dedicated to the project. To achieve this, CVM adheres to the following guidelines and procedures for faculty research effort on sponsored projects:

• Tenured or tenure-track faculty should not exceed 95% effort on grants, since faculty members have responsibilities outside of research (e.g., teaching, service or other academic activities). • For the PI and all personnel, the percent effort included in the budget of the sponsored project must accurately represent the necessary effort to complete the work based on an “average” work week. For faculty, this “average” number is likely to exceed 40 hours and may vary from one week to another. Examples: Faculty A: Commits 10% effort in a grant proposal and works 40-hour weeks on average 10% x 40 = 4 hours/week on average Faculty B: Commits 10% effort in a grant proposal and works 60-hour weeks on average 10% x 60 = 6 hours/week on average It is not required that faculty keep track of hours on a weekly basis but they are expected to maintain a good estimate of how their time is spent over the reporting period. It is also recognized that research, teaching, and clinical duties are often inextricably intertwined and faculty are only asked to estimate their relative contributions. • Unless specifically prohibited by the granting agency, faculty are required to seek compensation as percent of base institutional salary that is identical to percent effort dedicated to the project (e.g., 50% effort on a grant would generate 50% of University base salary and fringe benefits). Allowable Sponsored Research Activities For faculty effort reporting, activities are classified as either sponsored activity (e.g., grants, contracts, cooperative agreements) or other, non-sponsored activity (e.g., teaching, service, clinical, administration). Examples of sponsored activity include: research and research training of individuals related to the sponsored award; and reasonable amounts of work contributing to the award, such as presenting seminars, writing manuscripts, developing scientific and regulatory protocols, providing lab oversight, and attending meetings and conferences. Examples of non-sponsored activities include: proposal preparation, instruction, committee work, and other administrative functions including service on review or advisory panels.
  Cost Sharing of Faculty Research Effort Cost sharing of faculty effort refers to the expenditure of institutional resources beyond the amount funded by the sponsor to support the scope of research outlined in the sponsored award. As a general rule, cost-sharing of faculty effort is strongly discouraged as state funds should not be allocated to sponsored research and cost-sharing negatively impacts the indirect cost rate for federal grants. However, there are three situations that may warrant exceptions to this rule. • “Over-the-cap” Cost-Sharing. Faculty salaries funded by the U.S. Department of Health and Human Services (HHS) agencies are subject to limitations established by the federal government. As of January 1, 2023, the faculty salary cap is set at $212,100. This is the maximum amount of faculty salary that can be charged to an agency’s award, with any remaining salary to be paid by the institution in the form of cost-sharing. • Mandatory cost-sharing. Mandatory cost sharing is required as a condition of a specific solicitation/program announcement. It will normally appear in the award announcement from the sponsor and must be submitted along with the proposal. As required, such cost sharing expenditures will be tracked and reported back to the sponsors in a Financial Report. • Voluntary cost-sharing. Voluntary cost-sharing comes in two forms:
  ✓ Voluntary committed cost sharing is created if a proposal budget or budget justification specifically includes cost sharing where the agency does not require it but also does not provide salary support for the PI. In this instance, the PI and UF are “committed” to providing the project with the indicated support by requiring a minimum of 1-2% effort commitment for PIs to address Memorandum M-01-06 from the Office of Management and Budget (OMB) which states: “… 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). Such committed faculty effort shall not be excluded from the organized research base by declaring it to be voluntary uncommitted cost sharing. If a research program research sponsored agreement shows no faculty (or senior researchers) effort, paid or unpaid by the Federal Government, an estimated amount must be computed by the university and included in the organized research base.” (https://www.whitehouse.gov/omb/memoranda_m01-06) This law pertains to Federal funds, but for consistency we apply for all sponsors on all applicable proposals. While this commitment is not required to be explicitly stated in the proposal, it will be captured in UF’s management system and documented subject to audit. ✓ Voluntary uncommitted cost sharing represents contributions to a sponsored project made after the award is received. For example, the PI decides to spend more time on the funded project than proposed and not charge the sponsor for the increased effort. Uncommitted cost sharing is not planned and is not tracked in UF’s management system.
  Notably, all cost sharing, except “over the salary cap”, must be approved by the PI’s department Chair, Associate Dean for Research, and UF’s appropriate business official who have the authority to commit funds on behalf of the institution covering the cost. Accordingly, the PI should consult with these individuals early in the preparation and submission of the proposal to discuss the necessity and level of cost sharing support. To facilitate the gathering of these cost sharing approvals, the UFIRST-Proposal SmartForm has electronic routing capability to collect the required approvals. For additional information on cost-sharing, please follow the link (https://research.ufl.edu/dsp/proposals/budgeting/cost-sharing.html).