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FEC

Classification and Allocation of Effort

Effort and Instructionⁱ	Q: For purposes of effort reporting, what does "instruction" mean? A: "Instruction" means the preparation, evaluation, and delivery of teaching and training activities of the University, regardless of whether offered on a credit or non-credit basis. It also includes instruction-related activities such as thesis advice, mentoring of students and similar activities. Effort related to instruction is included in a faculty member’s total effort.
Proposalⁱ Preparation	Q: Are there times when a faculty member can either prepare a proposal or work on a grant on his/her own time? A: Yes, faculty effort devoted to proposal activity or grant work during a pay period when he/she is 'clearly' not being compensated by the UW is permissible. Grant activity in these cases is documented as third party cost sharing.
Mentoring and Sponsored Researchⁱ	Q: What about mentoring of students that relates to a faculty member’s sponsored research? A: Mentoring of students related to sponsored research is appropriately included in effort directly charged to a faculty member’s sponsored agreement. OMBⁱ Circular 21 states that charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences.
Effort and Administration	Q: For purposes of effort reporting, what does "administration" include? A: Administration includes effort incurred for services that benefit common or joint university or departmental activities or objectives in deans/chancellors' offices, academic departments or programs and divisions, and organized research units. This includes, but is not limited to, serving as dean, chair or center director, department/college committee activity and grant proposal preparation.
Effort and Personal Activities	Q. What about basic activities that are personal to a faculty member, such as voting, or completing effort reports, or expense reports? Do these activities have to be assigned to a category of effort? A: Activities such as these that are intrinsic to the faculty member's personal daily routine do not need to be separately funded and accounted for in the effort reporting system. These types of activities are not viewed as serving a separate university function or administrative purpose, apart from the research, teaching, clinical, or administrative function(s) in which the faculty member is otherwise engaged. It should be emphasized, however, that any effort that is associated with activity identifiable in its own right, such as proposal writing or departmental or university administration, even if it involves only the faculty member himself/herself, must be reflected in the faculty member's total effort. Moreover, should the "housekeeping" activities referred to in this guideline become more than de minimis in amount for any reason, it may be necessary to reflect them in an administrative or other category of total effort. Questions about whether activities come within this guideline may require consultation with your Departmental Administrator. Management Accounting and Analysis (Executive Director) at 616-1379 and Grant and Contract Accounting (Associate Vice President for Research Accounting and Analysis) at 543-8951 are available to assist in this consultation as needed.
Effort and Review Panels	Q: Is effort that is related to service on review panels or other advisory activities for federal sponsors included within my total University effort? A: No. Effort related to review panels or other advisory activities for federal sponsors that include an honorarium, per diem, and/or travel reimbursement by the federal agency need not be included in your total effort for effort reporting purposes. The University encourages such participation and does not require prior approval provided that should the activities involve time away from the University, approval for this travel is sought from and approved by the appropriate supervisor. Such activities should be reported annually on Form UoW 1461, Outside Professional and Public Activities.
Effort and Other University Activities	Q: How do I classify effort related to thesis committees, search committees, faculty senate committees or activities, admissions committees, and similar activities? A: Generally these types of activities are considered to be administrative or instructional in nature. To the extent such activities are de minimis in amount, meaning that in the aggregate their inclusion in or exclusion from total effort would not affect the percentages of effort allocated to sponsored research, separate tracking and funding is not required. Management Accounting and Analysis (Executive Director) at 616-1379 and Grant and Contract Accounting (Associate Vice President for Research Accounting and Analysis) at 543-8951 are available to assist in consultation regarding such activities as needed.
Effort and DSMBs	Q: Since the NIHⁱ is requiring Data Safety and Monitoring Boards (DSMBs) for many studies, can participation be funded as part of a grant? A: Yes, but only if participation of a DSMB member is specifically budgeted in the grant. Otherwise effort associated with DSMBs would be part of departmental activities.
Sample Effort Allocation Samples	Q: Please provide some effort allocation examples. Sample Scenario 1: Faculty member Harris has 3 grants proposed at 25% (Grant A), 25% (Grant B) and 50% (Grant C). He works the first month of the FEC cycle on Grant A. The second month, he works 50% on Grant A and 50% on Grant B. Months three through 6, he splits his time between Grant B (1/4 of his time) and Grant C (3/4 of his time). Over the course of the 6 month FEC cycle, his time averages out to the percentages proposed and committed. He may charge his grant at 25% (Grant A), 25% (Grant B) and 50% (Grant C) during the 6 months as proposed. Sample Scenario 2: Faculty member Lim has 3 grants proposed at 25% (Grant A), 25% (Grant B) and 50% (Grant C). She works half of the FEC cycle (3 months) on Grant A and the remainder of the FEC cycle, divides her time equally between grant B and Grant C. Over the course of the FEC cycle, her time averages out to 50% for grant A, 25% for Grant B, and 25% for Grant C. For grant A, she either has voluntary uncommitted cost sharing of 25% (she only proposed 25% effort) which is reported under “all other activities” in the effort reporting form and/or may charge the additional 25% effort to the grant if funding is available. For Grant B, she may charge the 25% as proposed. For Grant C, her salary needs to be reduced from 50% to 25% before her effort is certified at 25% and if sponsor approval is required, she needs to seek permission for this 50% reduction in effort. Sample Scenario 3: Faculty member Findley has 2 grants proposed at 75% (Grant A) and 25% (Grant B). She spends the first month of the FEC cycle (6 months) setting up equipment that supports both grants A and B. She spends the remainder of the FEC cycle working 75% on Grant A and 25% on Grant B. The equipment setup time should be allocated in accordance with the benefit each grant derived from the equipment. The benefit can be based on estimates, e.g., an objective or subjective assessment of use such as hours of equipment usage, PI Findley’s effort to each grant, etc.
WOS	Q: I am a member of the research faculty. For the last few years, I’ve been 100% appointed/paid with 50% of my effort and pay on grant A and 50% of my effort and pay on grant B. I’ve been working approximately 30 hours on grant A and 30 hours on grant B and receive $70,000 salary on each for a total of $140,000. Next month, grant B ends and my department is unable to bridge any of my lost salary. What are my options: Option 1: Reduce salary to $70,000. Continue to work 60 hours per week but spend all 60 hours on grant A. Your salary total of $70,000 can be paid from Grant A because 100% of your effort is on grant A. (NOTE: If funding is available from Grant A, salary may be bridged from grant A). Option 2: Reduce salary to $70,000. Reduce work hours to 30 per week and spend all of those 30 hours on grant A. Salary of $70,000 can be paid from Grant A because 100% effort is on Grant A. Q: If I reduce my time to 30 hours as in option 2, can I teach a University class or devote my time to clinical activity in my spare time? A: Yes, if you can obtain funding. The percentage of your effort spent on teaching or clinical activity must be funded by University sources other than sponsored projects.
Part time	Q: What if someone is not funded 100%, i.e. has a 50% appointment and has a grant that funds 50% of their full time institutional base salary (meaning it would be the total of the 50% appointment). It would seem the 50% grant commitment means she can only devote 50% of 20 hours, instead of 100% of 20 hours. Am I misunderstanding something? A: Yes. The confusion lies with the idea she is certifying to the FTE level rather than the compensation level. The individual would be certifying to 100% of her compensation being supported by the grant which represents ½ FTE.
De Minimis	Q: I am With Out Tenure (WOT) and work 100% time on sponsored research. I am asked to serve on an instructional board of the UW. Besides periodic 3-4 hour meetings, there will be time/effort responding to queries, emails etc. Suppose this adds up to 10 hours per year. I work on average 60 hour per week. There is no compensation for this, and I believe this is part of my general “academic responsibility” and being a good citizen. Is my participation in this activity legal? Explain why or why not. Same question, but now I am asked to serve on instructional committees for one of my joint appointment departments. One request is to run an entire course, that I estimate will take 6 months prep time at 40% effort and 50 % effort during the quarter the course runs. The department is prepared to offer me 25% salary during the quarter I teach. How do I account for this activity? A: The term we use to identify effort that is too low to quantify is de-minimis. This term does not specify nor quantify a specific number of hours or percent of effort. To decide if an activity can be considered de-minimus, determine if, in the aggregate, its inclusion in, or exclusion from, total effort would affect the percentages of effort allocated to grant funded activity. If it would affect the percentages of effort allocated to grants, you should adjust the percentage of salary paid on the grant(s) commensurately. In the second scenario, it is evident that the percent of salary is not commensurate with the percent of effort required to accomplish the assignment. In this case additional non-grant funded salary needs to be identified to support the level of effort required. Q: What is the de minimis time that can be charged to a grant for non-sponsored activities without being non-compliant? For example, if a faculty does not have teaching or administrative responsibilities but attends faculty and division meetings that require less than 1% of their effort, is that de minimis? A: There are no set parameters to define what constitutes ‘de minimis’ activity. This is situational and must be determined by the faculty member in consultation with appropriate departmental leadership. In general, an activity can be considered de minimis when, in the aggregate, its inclusion in or exclusion from total effort would not affect the percentages of effort allocated to sponsored activity.
100% Research Faculty	Q: What provision is made to provide money for grant application/proposal preparation for research faculty paid 100% on federal NIH grants? What is the source of the funds and who is responsible for providing those funds? What provision does the UW make for service on the Faculty Senate by 100% federally funded research faculty? What provision does the UW make for service on the Human Subjects IRB by 100% federally funded research faculty? Who is responsible for assuring that those provisions for funding are in place? What certification exists in the FEC reports for those responsible officials to assure that the funding is available and utilized? A: Faculty should consult with their department administrator and chair to determine the source of funding for non-grant activities. Generally any departmental/school sources including but not limited to indirect cost recovery, gifts, endowments, and state funds may be used to fund these activities. Department/college administration is responsible for assuring that the provisions for funding are in place. It is not a function of the FEC reporting process to monitor or certify that funding is available. The FEC reporting process is for individual faculty members to provide assurance that the compensation paid from sponsored grants and contracts is equitable to the effort expended on those agreements as a portion of the total UW activity of the individual.
Part time 100% grant funded	Q: Chairs I am talking with vehemently believe that faculty on soft money are on soft money, without a departmental commitment. The argument I am hearing is that for part-time faculty their “off” time isn’t compensated regardless of what they are doing. I want to do the right thing, but the outcome may be to no longer permit part-time faculty to be paid only from soft money. A: Salary support for teaching, administration, service, clinical activity, institutional governance and proposal preparation effort must come from non-sponsored funds.
Emeritus 40%	Q: An emeritus faculty has been hired back at a 40% appointment (maximum allowed for retired employees) to teach. Can this individual “volunteer” time on a sponsored research project. A: No. Even though the faculty member is on a 40% appointment the same principles for Without Salary (WOS) faculty are applicable. The effort attributable to the sponsored project must be considered part of the compensation of the individual. It could be implied that by approving the application for the grant that department officials have approved a change in the scope of the appointment to include research.
Funding Sources	Q: Do I need a separate funding source for each teaching, administrative, clinical and/or service activity in which I participate? A: No.While salary related to sponsored activity must be distributed to individual grants/contract budgets at the percentage of total University activity on those grants or contracts or at a smaller percentage, non-grant activity can be funded by one or many funding sources (e.g. if 20% of University activity is teaching and 20% is administration consisting of involvement in an IRB, proposal writing, and search committees, the 40% can be funded entirely by one or several non-grant budgets. Q: What non-grant funds can be used to support the activities that can’t be charged directly to grants? A: Virtually any University budget that doesn’t have other restrictions placed on it by the funding source including State and Research Cost Recovery funds. Gifts and endowments are appropriate sources if the activities are consistent with donor intent.
% of Non-Federal Sources Required for University Activities	Q: If we set a college or departmental policy and pay everyone a set percentage (e.g. 5%) from non-grant funds, have we met our commitment? A: While the percentage you set may be the right funding mix for some, others may work significantly more or less on non-grant activities. So, while considering removing everyone from grants for some portion of their time may reduce your risk, every individual’s portfolio of activities should be reviewed to determine the appropriate mix of grant and non-grant funding. The final determining factor is each individual’s actual effort.
Risk Areas	Q: What risk areas should we focus on as a school, college, or department? A: The following areas are receiving significant attention nationally: 100% research faculty – are they involved in activities that should be funded by sources other than their grants? Faculty with 5 or more federal awards – are they overcommitted? Are the percentages of salary distributed to each of their projects reasonable? Change in Level of Effort – are faculty seeking prior approval from the sponsor to change the level of effort proposed in their grant when required (typically when the change is 25% or more)? Faculty with 1 or 2% of their effort on many awards – are they contributing the effort promised? Faculty Effortⁱ Certification – is it timely? Salary Expense Transfers (OSETs) – are they infrequent, but timely when necessary? Of particular concern are those affecting time periods for which faculty have certified their effort. Total effort commitments (paid and cost shared) to the sponsor – are they met? University effort reporting policy – is it being followed?
Effort and Intellectual Property	Q: Is effort related to pursuing intellectual property (e.g. making an invention disclosure, meeting with UW’s Tech Transfer Office to discuss an invention disclosure, meeting with a patent attorney about a UW invention, reviewing internal action on a patent application and/or reviewing a draft patent application) on UW awards included within my total University effort and can it be directly charged to grants? A: Yes, consistent with the spirit of the Bayh-Dole Act, reasonable levels of activity related to pursuing intellectual property can be charged directly to the appropriate grant. As with any effort charged to sponsored agreements, effort associated with the pursuit of intellectual property must be directly related to the sponsored project that is being charged. Where more than one award or activity contributed to the development of the intellectual property the effort distribution should be based on proportionate support provided under the awards or other equitable relationship. The effort must also occur within the award period for it to be eligible for direct charging. These activities should be included within total University effort for effort reporting purposes.
Minimum Effort for Key Personnel	Q: Is there a minimum level of effort required for key personnel in grant applications? A: Some level of effort must be noted in the grant application for all key personnel. Most sponsors will accept the level of involvement of key personnel to reflect “as needed” except NIH. NIH defines key personnel as the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Therefore, an “as needed” level of effort is not acceptable for NIH grants. There is not a required minimum level, it is only required that the effort be measurable.
Other Significant Contributors	Q: Can a faculty be noted as contributing to a grant without committing effort? A: Yes. NIH grants now have an “Other Significant Contributors” field available. This allows the PI to identify individuals who have committed to contribute to the scientific development or execution of the project but are not committing any specified measurable effort. The following is a quote from GIMⁱ 21: "if personnel have been asked to perform effort occasionally for an undetermined but incidental amount of time on a grant, a description such as 'participate in the design of test methodologies' or the term 'as needed' should be used in the proposal instead of dollars and/or percentages."
Average Work Week	Q: I am currently a research faculty member at UW. I often tend to work 50 or sometimes even more hours per week. The precise number changes from week to week and month to month and reflects the uneven nature of research, teaching, and administration. It appears that the admission of working extra hours can only penalize an individual. As an example, faculty members A and C receive the same amount of money from the grant ($37,500) and perform the same number of hours’ work (10 per week) on the grant. It seems, because C works more total hours, s/he is receiving too much money from the grant as his/her grant hours represent a smaller percentage of his.her total hours. Therefore all faculty members should take care not to work more than their allotted hours per week. Am I correct in making this conclusion? A: Unless specified in the letter of appointment, the University does not specify the number of hours per week a faculty member must work. There is an expectation that members of the faculty will work the hours necessary to carry out the professional responsibilities of their position. Faculty appointments generally specify an annual salary amount that is negotiated between the department/college and the individual faculty member. This salary is not divided into the various responsibilities of the faculty member such as instruction, research and administration. The assumption is that each of these responsibilities is of equal relevant value. In other words if your time is expended in a ratio of 1/3 to each activity, 1/3 of your salary could reasonably be attributable to each of the activities. To illustrate this further, if the salary were reduced to an hourly rate, that rate would be the same for each of the areas of responsibility. Therefore sponsors expect that the salary charged to their project for the effort performed will be at the same rate as the salary charged to other activities performed by the faculty member. Effort on grants is to be based on your total university effort. The principle is that sponsors are not to be charged at a higher rate per unit of effort than the institution pays an employee for effort directed towards other University activity. The percent of salary allocated to your grant should be commensurate with the percent of your total university work effort, directed towards the goals of the grant. This principle demonstrates that regardless of the activity engaged in for the University, the compensation for that effort is at a consistent rate.
Allocation of effort on grants	Q: I understand that Schools and Colleges are responsible for working with faculty on issues related to allocation of effort on grants. A:Yes. Links to these documents are available on the References page accessible from the Faculty Effort Certification (FEC) website in the Quick Links section.
% Effort on FEC	Q: The faculty effort certification (FEC) form only reflects percent distributions and not salary dollars. What is the reasoning behind this? A: The FEC is the University of Washington's method for faculty to certify their effort on federal and other sponsored projects. The Federal government requires periodic confirmation that the percent distribution of salary represents a reasonable reflection of the faculty member's percentage of effort. The key is percent, not dollars. Since many times it was found that adjustments were being made based on dollars rather than percent and that the adjustments did not result in percent effort commitments being met, the dollars were removed from the version of the FEC faculty will certify. FEC Coordinators and faculty have a working view called the online FEC which does reflect dollars and provides drill down capability to individual transactions. After all necessary adjustments are made using the detailed view, the faculty certify the Summary FEC which reflects only percentages.
Fixed Price Surplusⁱ	Q: How are residual balances in fixed price contracts handled? A: All sponsored budgets, regardless of the sponsor or the agreement type, should only be charged the expenses necessary and allowable to meet the objectives of the project. In the case of fixed price agreements, any true residual balance, i.e. the awarded amount less expenditure booked, should be transferred to a fixed price surplus budget, 05-34. The fixed price surplus budget is not considered a sponsored agreement and will therefore appear in the “Other Salary Source” section of the FEC. Extensions of fixed price budgets may be granted but only for the purpose of completing the original project. They should not be extended for the purpose of “spending down” a true residual balance.”

Charging Salary

Funding Grant Proposals	Q: How is the effort I spend preparing my next grant proposal funded? A: During the effort reporting period in which you prepare the proposal, the percentage of effort spent on proposal preparation must be funded by University sources other than sponsored projects. An exception to this is when salaries are charged to a Research Career Development (K) Awardⁱ.
Funding Grant Proposals for 100% Research Faculty	Q: What if there is a 100% researcher and s/he is going to apply for a new grant? How is that person to be paid for the time that will be devoted to preparing the proposal? A: A portion of salary consistent with the effort required for preparing the proposal should be paid from non-federally funded sources like State, RCR, Gifts, Endowments, or DPA during the period when the faculty member is writing the proposal. An exception to this is when salaries are charged to a Research Career Development (K) Award. The percent should be consistent with percent effort spent on proposal preparation.
100% Research and Other Activities	Q: What if that same person teaches or is involved in other scholarly activities and is 100% funded for research. Is that okay? A: Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. If the teaching and other activities are NOT contributing and intimately related to the work under the agreements that are paying the salary then a portion of the individual’s salary proportionate to the non-grant effort must be paid from other non-federal sources.
Appropriate Source of funding for Grant Writing	Q: Can a faculty member use a non-federal sponsored funding source (i.e. pharmaceutical dollars) to cover their grant writing effort? A: No. While not all non-federal grants/contracts are subject to the same rules as federal grant/contracts we are still bound by the cost accounting standards and the issue of consistency in how we classify costs. These costs are specifically noted in OMBⁱ Circular A-21ⁱ as indirect and we must be consistent in classifying them as such. In addition, it could be viewed as a violation of our fiduciary responsibility to expend the non federal sponsor funds in a manner that does not directly benefit the project they are intended to support.
Minimum % Required for Proposal Prep	Q: Is there a “policy” or “point of clarification” on the minimum appropriate percent of effort needed for grant writing? I recall at a meeting that 2.5% and 5% were thrown around as possible minimums. A: There is no guideline or directive from the UW (or the federal government) on the minimum appropriate effort for grant writing since it varies broadly by faculty member. The level of effort should be based on each faculty member’s individual situation and actual experience.
Extended Leave	Q: What is the procedure for paying University employees assigned to work on a grant or contract when they must take extended leave (sick leave, maternity leave, family leave, vacation, etc)? What about effort reporting? What about unpaid leave? A: Per UW policy, paid absences are to be charged to the same budgets and in the same proportions while an individual is on leave as they were immediatly preceeding the individual going on leave. The effort report will continue to be reported based on the salary distribution. Example: An employee’s effort/salary was 50% on a departmental budget for teaching and 50% on a research grant prior to taking paid leave. During the period of leave the salary should continue to be charged 50% on the departmental budget and 50% on the research grant until the individual returns to work or through the end of the grant period. On the effort report, the pay and effort will continue to be reflected at 50% on the departmental budget and 50% on the grant. Note: Unpaid absences are not reflected on the Faculty Effortⁱ Certification (FEC) form. However, extended leave may impact the level of effort committed to the project by key personnel including the Principal Investigator/Project Director. The sponsor must pre-approve any leave that lasts for a period of 90 consecutive days or more for the PI or key personnel. In addition, should a partial leave result in a reduction of time devoted to the project of 25% or more of the original commitment, prior sponsor approval is required. The Principal Investigator should submit to the sponsor, through OSPⁱ a request for approval to be absent from the project or reduce their time devoted to the project.
Vacation	Q: What about vacation time when there are multiple grants. How does one ensure that each grant pays their fair share of vacation time? A: The University applies a consistent practice of paying vacation & other accrued leave from the funding in place at the time the leave is taken. If grant funds are not being used to support the individual at the time leave is taken the department must cover the leave costs. This is a fairly common practice at institutions and is viewed as acceptable because we are consistent in the application and do not discriminate between funding sources.
WOS New Faculty and Proposal Prep	Q: We have a new research faculty coming aboard. We are offering him a With Out Salary (WOS) appointment as we can’t fund a new Faculty who has no independent funding. It’s clear, once he has started, if he is doing grant writing we will have to fund that effort (e.g., 5%). Question – If he has written a grant and submits it prior to his faculty start date – are we required to fund 5%? A: No. The issue at hand is “compensated” effort. That is, if an individual is being compensated by the University and writes a grant proposal this is considered part of the individual’s University effort and therefore some portion of his/her compensation would need to be charged to other than grant/contract resources. (The percentage applied should reflect actual effort devoted ot proposal writing, i.e. the 5% noted above should be used if that is the actual effort involved.) If he/she is not being compensated and/or there is no grant/contract effort, there will be no FEC generated. Writing a proposal does not require the University to pay someone who is not already being compensated.
IBS	Q: We are in the middle of a 5 year award. When we submit our budget for next year should we use the definition of Institutional Base Salary ⁱ(IBS)? A: Yes. The current definition of the IBS is clearly outlined in the FEC training and documented in GIMⁱ 35. This definition should be incorporated with all new budgets.
ADS/ENS	Q: What is the basis for having ADS and ENS in the base salary? A: Federal regulations define institutional base salary as “The annual compensation paid by an organization for an employee’s appointment, whether that individual’s time is spent on research, teaching, patient care, or other activities. Base salary excludes any income that an individual is permitted to earn outside of duties for the applicant/grantee organization.” As ADS and ENS are considered part of an individual's annual compensation, they are included as a part of the institutional base salary.

Managing Effort

Reduction or Increase in Effort	Q: Is it sufficient for a faculty member to simply tell his/her Program Officer about a change of effort of 25% or more of current (committed) effort? A: While it is important that the researcher maintains a good relationship with the Program Officer, this is not sufficient. Any decrease in effort of 25% or more by key personnel (as noted in the Notice of Grant Awardⁱ) must be approved in writing prior to the change by the sponsors’ *Grants Officer. The request must be processed through the UW Office of Sponsored Programs in advance of the change. An increase in effort greater than 25% for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored agreements. Any change in the scope of work must also be approved in writing* prior to the change by the sponsors’ Grants Officer. The request must be processed through the UW Office of Sponsored Programs in advance of the change.
Post Award Salary Changes Affecting Effort	Q: After the grant is awarded, I often find that either my salary has increased or my colleague’s salary has increased by more than the 3-4% (NIHⁱ allowed) from the time of writing the proposal to the time of award. For example, I propose 10% effort and my salary at the time of application is 100K therefore I have budgeted 10K. At the time of my award, my salary is 120K. If I charge the grant for 10% effort (12K), I will be in deficit from day one! In these events, can I reduce my % effort so that I match the dollar amount charged? From the website, it seems I can reduce my effort as long as it is not 25% or more. Does this situation justify it? Alternatively, I can keep my % effort but reduce the amount charged to the grant and the rest of it comes from department funding. Which option should I use? A: The focus should be on the required level of effort to accomplish the objectives of the project/program as it was proposed. If a reduced level of effort will not impact meeting the project/program objectives then that would be the most appropriate course of action. However, if the reduction is 25% or more you will need to obtain agency approval. If the proposed level of effort is required and funds are not available from the award, then non-grant funding could be used to ‘cost share’ some effort. Another option would be to approach the sponsor for additional funding or for a change in the scope of the project, if the level of funding cannot support the project due to inflation in the associated costs. To avoid or lessen the incidence of such situations it may be necessary to apply an inflation factor to the salaries used in proposals. If it is known that awards will not be issued for a significant time after proposals are submitted an inflation factor could be added to current salary levels for the first year of funding as well as each succeeding year.
Key Personnel	Q: “Key personnel” who require approval for 25% (or greater) effort changes are those listed on the Notice of Grant Award. My PI has brought me copies of Emailed Notice of Grant Award and it is silent (aka not listed) as to who is key personnel. What direction should we take? Do we assume no one is key personnel? Do we assume all those listed on the Budgetⁱ proposal are key personnel? A: Key personnel are defined as the PI or key personnel specifically named in the Notice of Grant Award (NGA). If the NGA is silent the PI, by default, represents the only key personnel for the award. Prior approval is required if key personnel withdraw from the project entirely, will be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of award. Prior approval for a change in status pertains only to the PI and key personnel named in the NGA regardless of who may be designated as key personnel in the grant proposal.
Medicare Cost Report	Q: Does the faculty member need to worry about how the Medicare Cost report that s/he fills out twice a year compares to their FEC report? A: The faculty member needs to be mindful of all information s/he uses to describe his/her activities. However, since the Medicare report is a snapshot of 2 weeks every six months, it may vary from information reflected on an FEC which is averaged over a six month reporting period.
Faculty Evaluations	Q: What about background materials that are part of periodic faculty evaluations? Will these materials conflict with the FECs? A: Once again, the faculty member needs to be consistent when thinking about his/her time and accurately depict those times in every report s/he completes.
No Cost Extensions and Effort	Q: What are the effort requirements of a PI for a no-cost extension under Expanded Authorities? Does the original effort commitment extend to the no-cost extension period? Does the PI need to request permission to reduce his effort or does the institution have the authority to approve the reduction of effort when approving the no-cost extension? A: From a strict policy stand point, the terms and conditions continue unless amended, so reducing effort by 25% or more would require sponsor approval. K awards present a particular case as they generally carry the requirement for a 75% commitment of total professional effort. Additionally, reductions below 50% for a no-cost extension require sponsor approval. The PI may, however, request that the sponsor approve eliminating or reducing the cost share during the no-cost extension process. While the University may approve the no-cost extension, the reduction of effort must be granted by the sponsor.
Direct Charged and Cost Shared Effort	Q: A PI in our department has 20% direct charged effort and 10% cost sharing on one of her federal grants. She wants to reduce her effort on the cost share to 5%. Is this OK? A: When committed effort involves cost sharing, the total amount of direct charged plus the amount of cost share equals the total effort requirement, in this case 30%. The faculty member may reduce her effort by 25% or less without requesting prior sponsor approval, however the reduction of effort should be applied proportionally to both the direct charged effort and the cost shared effort. Q: Could this PI charge 15% effort to the grant and cost share 15%? A: Yes, The relationship between the amount of effort charged directly to the grant and the amount cost shared is secondary to the PI meeting the combined (total) percent of effort.
Reduction of Cost Shared Effort	Q: When there is a reduction in effort for an individual with both cost shared and directly charged salary, to which component does the reduction apply? A: If the cost share is committed based on effort, and necessary approvals have been obtained (e.g. reduction of 25% or more), the reduction should be prorated proportionately over both the direct charged and cost shared effort. If the cost share is mandatory, specific approval from the sponsor is required unless other sources of cost sharing are permissable and substituted.

Changes in Effort

Recertification	Q: My faculty member certifed her FEC but now has discovered a change in effort requires her to recertify. Can the corrections be made and she recertify a new corrected FEC online through the eFECS system? A: No. If salary or cost share changes occur after the original certification, the FEC will need to be manually corrected and recertified by the faculty member. Step by step instructions to recertifying an FEC may be found on the FEC website uneder "Recertifications."
Documentation	Q: An online salary expense transfer (commonly called an OSET) was processed for my faculty member after he certified his effort. What documentation do I need to attach to the FEC to support this change? A: Attach the version of the OSET that states "Transaction has been posted." Versions that reflect "Transaction has been submitted" will not be accepted as there is no confirmation that the salary transfer was completed and posted to the system.
Overpayments	Q: After my faculty member certified his effort, it was discovered that he was overpaid. What documentation do I need to attach to the recertified FEC to support the reduction in his salary as reflected on his originally certified FEC? A: Attach a signed Overpayment/Repayment Option form and a copy of the departmental worksheet that shows the pay periods when salary was deducted. You may also attach the HEPPS records (List Funding History by Employee, screen 3/35 with the dates of the cycle) or OPUS records (List Funding with the dates of the cycle) if these support the overpayment. Note, if the distribution of the repayment is in the same proportion as the FEC percents, i.e. was credited back to all budgets in the same proportion as it was originally paid, there may not be a need to recertify the FEC.
OSET Documentation	Q: I did an online salary expense transfer (OSET) which transfers salary into a budget that does not appear on the FEC. How does this get reflected on the FEC? A: If the OSET is completed before the faculty member certifies the FEC, eFECS will reflect the salary transfer on the online FEC, normally the day after it posts.
Fluctuations in Level of Effort	Q. Can a PI reduce his/her effort during an FEC cycle by 25% or more if the total effort during the budget period is compliant with the commitment on the grant? Does the PI still have to contact the sponsor for prior approval? A: Normally effort should be met over the budget period, not necessarily over each FEC cycle. Effort may vary from FEC cycle to FEC cycle as long as the PI(s) or key personnel as designated in the NGA do not absence themselves from the project for three consecutive months or more, or reduce effort on the grant (direct and cost shared combined) by 25% or more over the budget period. have an NSFⁱ grant where there is summer salary where effort is required to be averaged over the quarter. Unless one or more of the three issues noted above apply, there is no need to request prior approval from the sponsor for fluctuations in effort.
Salary Transfers and Sub Budgets	Q: We have two faculty who are working on a grant in our department. We just set up sub budgets for this grant and plan to redistribute their salaries. They have already certified their FECs for the last cycle. Do they have to recertify these FECs? A: No. Recertification of the FEC is only required if the level of effort on the sponsored "project(s)" changes. Documenting the transfer of salaries to a sub budget number is not required as long as it does not change the percent effort on the project for the respective FEC cycle. This includes salary transfers from a parent budget to a sub budget or a sub budget to another sub budget within the same project.

Nine Month Appointments and Summer Salary

Cap Cost Sharingⁱ during Summer	Q: I have a faculty member who has a 9 month appointment and is working on her NIHⁱ award in the summer. She does not have departmental support during the summer and therefore cannot meet the salary cap cost sharing required. Can she do the cost share in another quarter? A: No. Salary cap cost sharing must be provided during the period in which the effort is performed and the salary earned. Therefore, it is advised that the department plan accordingly and identify non-grant funding to cover the cost sharing required by the salary cap in the summer.
Cost Share during Periods Not Compensated by UW	Q: I have a 9 month faculty member who wants to cost share in the summer when he is not paid by the University. Can he do this? If so, how should we set up the cost sharing? A: If a faculty member is engaged in compensated University activities during a pay period, that pay is considered compensation for all of the individual's University activities for that time period. If it is clear that no pay is received during a specific pay period, then “volunteer” effort by a faculty member on a federal grant or contract as third-party cost share is permissible. This cost share must be reported by the faculty member via a letter to GCAⁱ documenting the time spent on the project with the value based on their normal rate of pay. The letter should be signed and dated by the faculty member and countersigned by the PI of the grant if different. See Third party cost share reporting http://www.washington.edu/research/gca/costshare/third.party.html ) If, during an FEC cycle, a faculty member receives UW compensation for a portion of the cycle, e.g., 10 of 12 pay periods, and performs volunteer (i.e., non-compensated) effort for a different portion of the cycle, e.g., 2 pay periods, please indicate this in the 'Comments' section of the FEC. Note, indicating this on the FEC does NOT represent certification of the non-compensated effort rather it is for informational purposes only. The non-compensated effort must be documented as noted above just as any other third party cost sharing is documented.
Summer Salary	Q: I am still not clear as to how summer salary or other salary relates to your effort during the academic year and how to report this. A: The FEC process is conducted on a semi-annual schedule for faculty on 9 month appointments. Spring (3/16-6/15) and summer (6/16-9/15) effort is combined into a single FEC (March 16 - September 15). The rate of pay one can receive from a grant for work during the summer portion of this cycle is based on their 9 month academic year salary rate. While summer salary is considered part of institutional base salary, it is generally a unique line/designation in grant proposals. For example, if the 9 month salary is $3,000 per month for a full-time appointment and there is a commitment of 50% effort for two months during the summer portion of the spring/summer cycle, the rate of pay for those two summer months would be $1,500 per month for 50% effort per month. The summer compensation will be added to the compensation received during the spring quarter for each sponsored budget and for "Other Salary Sourcesⁱ." The percent for each budget will then be calculated by dividing the total compensation charged to the budget divided by the total compensation received over the two quarters, i.e., FEC period.
Administrative Supplements	Q: A faculty member has a nine month appointment, 100% state paid salary and during that time draws an endowed supplement (ENS). The state paid salary is $10,000 a month and the ENS is an additional $1,000 a month. Thus, IBS during these 9 months is $11,000. During the summer, this faculty member intends to devote 100% of one summer month effort to his/her grant. Does inclusion of ENS in the Institutional Base Salary mean the grant can be billed $11,000 a month, total of state salary and ENS? A: Yes. The endowed supplement is part of the IBS and would be included in calculating the grant proposal budget. Therefore, the salary paid over the summer would be based on the $11,000 monthly salary rate for the faculty. This is consistent with OMBⁱ Circular A-21ⁱ, J. 10d, 2, which states: “charges for work performed by faculty members on sponsored agreements during the summer months or other period not included in the base salary period will be determined for each faculty member at a rate not in excess of the base salary divided by the period to which the base salary relates. The base salary period used in computing charges for work performed during the summer months will be the number of months covered by the faculty member’s official academic year appointment.” The NIH definition of IBS makes it clear that NIH considers ALL compensation paid to an employee for ALL activities of the employee on behalf of the employing institution, as IBS. For this reason it has been determined that supplements, other than short term supplements, are a part of IBS. Q: In the example above, if the extra $1,000 during the 9 month is an administrative supplement and the faculty member will do NO administration during the summer, can the grant be charged $11,000 for 100% effort on the grant (all of it research, none of it administration. A: Yes. Same answer as above
NSFⁱ Academic Year Support	Q: Does NSF pay academic year support? A: Compensation for doing research is often included as part of a faculty member's regular salary and in those cases, academic year salary would not be appropriate. If, however, a faculty member has a teaching appointment, it may be appropriate to request academic year support. The caveat is that some NSF Divisions/Directorates have more restrictive policies with regard to academic year support than others. Therefore, the best thing to do is to check with the cognizant Program Officer to discuss the issue.
Summer Cost Share	Q: A grant with cost share started in the summer for one of my 9 month faculty and the budget is not showing up on the FEC. How do I document this effort? A: You should use the Predefined Comment on the FEC, "Faculty with 9 month appointment - summer cost share is committed." Put a note into the "Additional Comments" section that documents the added cost share and the adjustments for the totals and subtotal rows resulting from the addition of the summer cost share. Example Template: 61-1234, Start Date: xx/xx/xxxx % Summer cost share ___ Adjusted % in budget's cost share column ___ % Cost share on budget's total line ___ Adjusted % on subtotal Sponsored Programs ___ Adjusted % on subtotal Other Salary Sourcesⁱ ___

Salary Caps and Limitations

Salary Supplementation for K Awards	Q: What are the rules regarding salary supplementation for K Awards? A: Salary supplementation refers to additional funds the institution must contribute to make up any difference between the K award salary limitations and actual salary for the K Award-covered effort. For example, the required 75% effort for a faculty member with a $125K IBS would be $93,750. $93,750 (75% of IBS) -$75,000 (K Award salary limitation) $18,750 supplementation required. Generally this supplementation may not come from other PHS funds but other federal funds may be used with prior agency approval. If the federal funds come from a sponsored agreement, the objectives of that grant must not detract from but be complementary to the objectives of the “K” award. Non-federal sponsored funds may also be used as supplementation under the same criteria.
K Awards and Federal Support	Q: Can Federal support be used for salary above the K effort? A: The question of whether or not Federal support can be used for salary above the K award effort may actually depend on the particular K award. Some K awards actually require other NIHⁱ support. Others imply that since the K award experience is considered full-time there is no room for Federal funded activities outside of the K award activities. However, in most cases if only 75% effort is devoted to the K award, the remaining 25% can be devoted to other projects as long as they are K related and contribute to the K award experience.
K Award Re-budgeting	Q: A faculty member has 95% effort on a K Award. Can they decrease their effort on the K award to 75% and use the remaining 20% effort paid by the K to work on other projects that are "consistent with the objectives of the award"? A: No. It is not allowable to charge payroll to a K award for effort directed towards another project even if they are closely related. Q: In a K Award, can some of the research direct costs be re-budgeted to salary? For example, most K-23 awards include $75,000 annual salary + $25,000 annual research costs. Can one re-budget to, say, $85,000 annual salary + $15,000 annual research costs? A: The NIH does allow institutions to re-budget under Expanded Authorities within the total costs awarded to cover salary expenses provided the salary is consistent with the institution's salary scale. Care must be taken however as salary limits for NIH career awards are not consistent. Therefore, it is suggested one contact the NIH component to determine if a maximum contribution to the candidate's salary exists. Also, it is very important to acknowledge that the salary may not exceed the NIH salary cap. To illustrate, an individual with an annual (12 month) salary of $200,000 originally budgets 75% effort to a "Mentored Patient-Oriented Research Career Development (K23) Award." K23 awards provide for salary support from $75,000 to $179,700, the present NIH salary cap. Because of the salary cap the original salary awarded was $134,775 ($179,700 x 75%). If the recipient is actually contributing 85% effort then it is permissible to re-budget to accommodate the additional $18,660 in salary resulting from the increased effort (85% x $179,700 less $134,775 already awarded) provided the funds are available within the original budget award.
Salary Cap Increases	Q: Can the NIH salary cap increase during the life of a grant? A: Yes. If the NIH increases the cap, you can increase the salary line for a faculty member up to the new salary cap level if there are sufficient funds in the budget and the change is within the allowable re-budgeting parameters. To date, salary cap increases have always been made effective January 1. Q: What if the salary cap decreases? A: If the salary cap decreases it may be necessary to reduce salaries being charged to grants subject to the salary cap. The reduction that occurred in December 2011 required that nearly all new funding actions "issued" on or after 12/23/2011 for grants subject to the salary cap were restricted to the lowere salary regardless of project start date.
Salary Cap and Contingent Salaries	Q: Does the salary cap apply to faculty with contingent salary? A: In most situations, the contingent salary represents 100% UW compensation for 100% UW effort on an appointment that is not specified at less than full time. If the MOU or appointment letter specifies less than a full time appointment and the full time equivalent salary is greater than the salary cap, then the salary cap should be applied. For example, if the salary cap is $179,700 and a faculty member is receiving $150,000 for 100% effort, then he/she is not over the cap. However, if the MOU or appointment letter specifies 75% FTE, then the full time equivalent salary is $200,000 and the cap needs to be applied.
VA and PDR	Q: I understand the definition of IBS does not include paid direct dollars (PDR), including VA, and that these dollars should not be considered when determining whether a faculty member exceeds the salary cap. Is this correct? A: Yes, the University of Washington (UW) received confirmation from the NIH that VA salaries should not be considered part of the UW's IBS and therefore should not be included in the determination of whether an individual is subject to the salary cap limitation. This policy was adopted in the spring of 2005 and was made effective 12/16/04 to coincide with the start of the start of the winter quarter.
K Awards for VA/UW faculty	Q: The K-award section of the FEC training states that the VA appointment should be 2/8ths. I have a faculty member who has a 5/8ths VA appointment; can s/he still apply for a K award? A: Generally, we would like the faculty member to have no more than 2/8ths appointment at the VA if s/he is going to apply for a K-award. However if, after discussing with his/her Department Chair, it makes sense for the person to apply and s/he has 2/8ths but not more than 5/8ths VA appointment, approval may be requested by sending a letter to the SOM Dean’s office, Office of Finance and Administration/Departmental Support (Julie Reid).
K Awards and Proposalⁱ Preparation	Q: Can I charge time spent on proposal preparation for a research grant to my K-award? A: Yes. NIH, in consultation with the Office of Management and Budgetⁱ (OMBⁱ), has confirmed that limited charging of bid and proposal preparation, as a direct charge to a K-award, is allowable since it is the goal of these awards to train young investigators in all phases of research including preparing proposals.

Cost Sharing

Using a non-federal grant as a source for cost sharing	Q: A faculty member in my department has a non-federal grant for which she has permission from the sponsor to use as a source of cost sharing on her federal grant. How do I document this on the FEC? A: Some non-federal grant budgets do allow their funds to be used as a source for cost sharing. In these cases, complete the following: Verify the budget is an approved source of cost sharing. On the FEC: Use the predefined comment on the FEC, "Non-federal grant(s) approved to be used for cost share. In the "Additional Comments" section reflect the contributing budget(s) with percent contribution. Example Template: 65-1234 used as cost share source for 61-4321 % cost share__% * Adjusted % on federal budget's total line__% Adjusted % on non-federal budget's total line__% Adjusted subtotal on Other Salary Sourcesⁱ__% *This may be the same as the commitment unless adjustment of original commitment is necessary. This solution may also be applied in the rare instances when written approval from both sponsors has been obtained to use a federal grant as a source of cost sharing for another federal grant.
Salary Cap and Committed Cost Sharingⁱ	Q: I have a faculty member who has a 10% committed cost share pledge and 0.7% salary cap cost share requirement. Can the salary cap cost share be included as part of the committed cost share? A: No. Salary cap cost sharing is part of the original effort commitment. For example, if a faculty member committed 10% effort in his/her proposal but was over the cap, the sponsor would pay 10% of the cap and a non-federal, non-grant funding source would pay 10% of the difference between the cap and the faculty member’s total salary. This satisfies the original effort commitment. (Example of Methodology for Proposing Salary on an NIHⁱ Proposalⁱ When Salary Exceeds the NIH Salary Cap) Cost sharing is additional effort over and above the original effort commitment. For instance, if the faculty in the example above was to offer 5% cost sharing, that would be in addition to the original 10% commitment. . The faculty member would then owe 15% total effort on the grant. In the example above, the faculty member may have 9.3% of his/her salary paid directly by the grant 0.7% paid by a non-federal budget to satisfy the original 10% commitment and 5% funded by a non-federal, non-grant budget to satisfy the cost share commitment. 9.3% (Direct Charged to the Grant) + .7% (Cap Cost Share) + 5% (Committed Cost Share) = 15% (Total Effort Committed)
Salary Cap and K Awardⁱ Cost Sharing	Q: What about K award cost sharing? Can the cap cost sharing be used to satisfy the 75% effort requirement? A: Cap cost sharing, while it may not be used to satisfy mandatory or committed cost sharing that is based on effort, it does contribute toward fulfilling the original effort commitment. Cap cost share, therefore, can be used as part of the cost share necessary to document the required 75% effort required by the K Award.. Example: Dr. Einstein’s institutional base salary is $200,000 and the current cap is $186,600. Salary Cap Cost Sharing The sponsor will fund 75% of the cap 75% * $186,600 = $139,950 This creates a required salary cap cost sharing of $10,050 annually, or 75% of the difference between the salary cap and the institutional base salary K Award Cost Sharing The K award requires 75% effort and awards $75,000 in funding. 75% of $200,000 or $150,000 is required to meet the K award requirements. The cost share is the difference between the salary limitation and the amount required to meet the 75% effort $150,000 - $75,000 = $75,000 The Salary cap cost share, because it represents part of the original effort commitment, provides a portion of the total cost share. The total cost sharing required for this example is: Salary Cap: $10,050 K Award from other non-sponsored sources: $64,950 Total cost share: $75,00
Cost Share Totals	Q: Where can I check actual cost share figures? A: Both pledges (commitments) and actual cost share figures can be reviewed in the eFECS Cost Share Module.
Cost Share Codes	Q: What do the letters M, R, and S stand for in the eFECS Cost Share Module? A: Cost share in this system is coded M (Mandatory), R (Committed) and S (Long Term Shift in Funding Source).
Voluntary Uncommitted Cost Sharingⁱ	Q: A faculty member in our department performed more effort than what was proposed on one of his budgets. Does he need to declare this as cost sharing? A: No. This is referred to as “voluntary uncommitted cost sharing” (formerly called “other voluntary cost sharing”) and is captured in the Other Salary Sourcesⁱ section of the FEC. The federal government does not require voluntary uncommitted cost sharing to be documented.
Cost Share Summary	Q: How can I tell if we have met the cost share requirements on a particular budget? A: This information can be found in the Cost Share Module under the specific budget. For cost share For cost share committed in dollars, if the actual dollars equal the pledged dollars, cost share requirements have been met. These figures include salary, benefits and related Facilities and Administrative (indirect) costs. For cost share committed in percent effort, if the actual percent certified meets or exceeds the pledged percent, cost share requirements have been met.
Cost Share Addendum and Cost Sharing	Q: The Cost Share Addendum (formerally called the eGC1 addendum) provides the data to record cost share commitments in the Cost Share Module, which in turn is reflected on the FEC as cost share. This information is not updated and is not always correct. How does this meet the compliance requirements? A: If the amount of the award is reduced, the department should work with OSPⁱ to determine if the sponsor should be contacted to reduce the amount of cost sharing accordingly. Once this is done, and confirmation is received from the sponsor OSP will issue a revised electronic post award change (ePAC) that GCAⁱ will use to adjust the cost share commitment. (Note: The department needs to provide a new Cost Share Addendum.) GCA will then update the Cost Share Module which will result in the FEC reflecting the corrected amounts as long as the FEC has not been certified. If the department chooses not to contact the sponsor to reduce effort, the faculty member is obligated for the effort committed in the proposal even if the award was reduced. Departments should always review the cost share commitment set up in the Cost Share Module at the beginning of the grant to ensure it is what the department expects to see.
Carryover of Cost Sharing Deficitⁱ	Q: If a department has multiple faculty performing cost sharing on a grant that lasts three years and during year one does not meet the cost sharing, can the department carry over the deficit (shortfall) into year two? Do they need prior permission? A: Unless specifically stated in the award or by sponsor policy it is generally not a requirement that cost sharing be met evenly throughout a project (i.e., year to year) although sometimes there are those expectations.
Adjustments Between Effort and Non-Effort Cost Share	Q: I am a PI with a grant that requires a dollar match. Since supplies for this project were significantly more than anticipated, I would like to use these charges to satisfy the cost sharing instead of my originally proposed effort. Is this OK? A: Yes, with the following caveat. Regardless of whether the cost sharing is percent effort or dollars, if there is a specific commitment of effort by the PI or other key personnel, and the re-budgeting is caused by or results in a significant reduction (i.e. 25% or more) of that commitment, prior approval from the sponsor for this change needs to be obtained. Additionally, significant adjustments between effort and non-effort categories may imply a scope change. If this is the case, the sponsor must be contacted to approve the change.
Shifts in Funding Source	Q: What should happen when a faculty member maintains the committed level of effort but shifts how this effort is funded from the grant to other sources? A: The committed effort not funded by the grant becomes a cost share commitment. For example, a faculty notes 20% effort on a proposal with requested funding for the full 20%. After the proposal is awarded, the PI discovers a need to reduce his/her compensation from the award (gets paid at 15% from the award) but does not reduce his/her effort committed to the award (still at 20% effort). This creates a 5% cost share situation which should be documented on the FEC. Q: If a shift in effort funding creates a cost share commitment does a Cost Share Addendum need to be submitted? A: If the cost share commitment is for longer than six months, Cost Share Addendum, with administration approval, must be submitted to GCA. Note the Cost Share Addenudm need not be submitted to OSP. For cost sharing of six months or less, no Cost Share Addenum is required. The cost share should be noted on the FEC report along with a comment noting the faculty member’s level of committed effort.

Other

Whiteout and Tape

Q: I made a mistake when adjusting an FEC on for a faculty member in my department to recertify. Can I use whiteout to correct it?

A: No. Whiteout and white tape are a concern for auditors as corrections can be made to the form after the faculty member, chair, director, division head or dean has signed it. Cross out the incorrect information and write the correct information at the side. If whiteout is accidentally used, the faculty member needs to initial the change.

Rounding

Q: The individual budget lines on my faculty member's FED add up to 99%, but the total displayed is 100%. Should I change the total? A: You do not need to adjust total percent effort. All totals will round to 100%.

FEC Training

Q: How will FEC education be continued in our system?

A: GIMⁱ 35, “Effort Certification Policy for Sponsored Agreements” will continue to be available on the web. Additionally, there will be several trainings offered on a regular basis including FEC training for faculty through the Faculty Grants Management (FGM) training which PIs are required to complete every 4 years as well as various training opportunities for staff. Information and sign up for training on the eFECS effort module will be posted on the eFECS website at: https://f2.washington.edu/fm/efecs/training. Effort and cost share basics and compliance training will be offered by MAAⁱ and GCAⁱ. A list of the training sessions and reference materials can be accessed at http://f2.washington.edu/fm/maa/training. nformation on these will be sent to Department Administrators and FEC coordinators prior to each training opportunity.

Signatures and Initials

Who Can Sign the FEC

Q: The faculty member is out of the country. Can my administrator certify the FEC?

A: No. The administrator may not sign the FEC. Only the faculty member whose name is on the form or the department chair, director (of an organization or department level program), division head or dean may certify the FEC. Always send an informational copy of the FEC to the faculty member if someone else certifies in their behalf. Note: It is not permissible for chairs, directors, division heads or deans to delegate authority to certify FECs for faculty.

FEC Not Reflecting Salary Dollars

Q: I understand the Faculty Effortⁱ Certification (FEC) form only reflects percent distributions and not salary dollars. What is the reasoning behind this?

A: The FEC is the University of Washington’s method for faculty to certify their effort on Federal and other sponsored projects. The Federal government requires periodic confirmation that the percent distribution of salary represents a reasonable reflection of the faculty member’s percentage of effort. The key is percent not dollars. Since many times it was found that adjustments were being made based on dollars rather than percent and that the adjustments did not result in percent effort commitments being met, the dollars were removed from the certified version of the FEC (Summary FEC).

FEC Coordinators and faculty have a working view (screen) called the Online FEC. This screen reflects salary dollars and provides drill down capability to individual transactions. After all the necessary adjustments are made using this detailed view, the faculty will certify the Summary FEC that includes only percents.

Forms and Copies

Blank K Awardⁱ Addenum

Q: Where can I get a blank K Award Addendum to help me calculate the amount of K Award cost share owed?

A: Download and print this blank K Award Addendum.

Blank Salary Cap Addenda

Q: I did an RST that transferred expenditures into an NIHⁱ budget. Since the PI will need to recertify, where can I get a salary cap addendum to help me calculate the cost share owed?

A: Download and print this blank salary cap addendum.

Recharge Centers

How Are Overtime Charges Treated on Recharge and Cost Centers?

Overtime charges are allowable and are generally distributed proportionately to all activities during the time period in which they are earned.

e.g. Employee A, who is overtime eligible, works 20 hours on cost Center 14-XXXX and 30 hours on budget XX-XXXX for a total of 50 hours. Cost Centerⁱ 14-XXXX should be charge 40% (20/50) of both the regular earnings and the overtime earning for employee A. In addition, if employee A’s cost center activity involved more than one job for the time period, each job would normally share in the overtime earnings charged to the cost center.

Overtime charges can be recovered in two ways. 1) If overtime can be estimated with a high degree of certainty the incremental costs should be distributed to and included in the appropriate services prior to determining the rates for those services. 2) If overtime cannot be estimated with a high degree of certainty or is unanticipated the cost can be recovered through the next proposal cycle, via the over/under recovery adjustment. 3) The incremental cost of the overtime (overtime salaries plus the additional fringe benefits) can be added to the charges for ALL services (jobs) that employee worked on during the period of time the overtime was earned. Note, this is not a rate adjustment rather it represents only the actual incremental (additional) costs of the overtime.

Additional Guidance from Code of Federal Regulations

Grant and Contract Accounting and Cost Principles For Educational Institutions (OMBⁱ CIRCULAR A-21ⁱ/CFR 2 Part 220):

Grant and Contract Accounting website http://f2.washington.edu/fm/gca/faq/faq?tid=Expenditures

Frequently Asked Questions

Is it allowable to have overtime pay for a clerical staff person on our Dept of Energy grant, budget xx-xxxx? Clerical staff salaries are specifically approved as direct cost on this grant, because of our activity.

Federal regulations (A-21) do not disallow overtime for personnel other than the PI. However, unless the individual is assigned 100% to the xx-xxxx project, any overtime would need to be distributed to their other activity proportionately.

Cost Principles For Educational Institutions (OMB CIRCULAR A-21/CFR 2 Part 220)

http://www.gpo.gov/fdsys/pkg/CFR-2012-title2-vol1/xml/CFR-2012-title2-vol1-part220.xml

Section 10.b(1)(b)

(b) The apportionment of employees' salaries and wages which are chargeable to more than one sponsored agreement or other cost objective will be accomplished by methods which will—

(1) Be in accordance with Sections A.2 and C of this Appendix;

(2) Produce an equitable distribution of charges for employee's activities; and

(3) Distinguish the employees' direct activities from their F&A activities.

NOTE: Sections A and C discuss allocable, reasonable and allowable costs.

Imputing Revenues for Recharge and Cost Centers

Imputing Revenue for Recharge and Cost Centers – Imputing revenue represents the process of adjusting revenue to reflect an amount free from subsidies and other less than full reimbursements, e.g., bad debts, when determining future rates for recharging. In essence it adjusts revenue to assume full reimbursement from all users of the recharge/cost center. This is necessary to ensure the Federal government does not wholly or partially participate in the subsidies or other less than full reimbursements. Recovery of the subsidy would need to be done through non Federal sources and usually from non University sources. Most commonly this would be recovered from external users by crediting the center’s reserve budget or an alternate budget. Depending on the amount of the subsidy this could also be recovered over a period of time, e.g., 2-3 years.

Example:

Department contributes a $10,000 piece of equipment to a recharge center. In consideration of this the recharge center provides the department with $10,000 of unbilled service. For the current rate cycle the annual operating costs for the center were estimated to be $100,000. For determining rates for the next rate setting cycle the unit would need to determine their carry forward balance as follows:

Actual expenses for the year $101,000

Less:

Actual revenue (internal/external) (89,000)

Imputed revenue¹ (10,000)

Net (profit)/loss (carry forward) $ 2,000

¹Represents unbilled services to department in consideration of equipment purchase of $10,000

Mid-Year Equipment Purchases

Mid-year equipment purchases represent equipment acquisitions that do not coincide with the fiscal period of the recharge/cost center. As a result, they are sometimes included in the annual rate proposal if anticipated or are not included if they were not anticipated or not able to accurately estimate. In either situation, the following applies:

Depreciationⁱ for mid-year equipment purchases cannot be included in quarterly JVs until the equipment has been placed into service in the center and a new depreciation schedule has been approved by the Dean/VP’s office and MAAⁱ.

Special consideration should be given when any portion of the acquisition will be charged to a sponsored project(s) or the equipment will not be used 100% by the center. These situations should be discussed with your Dean/VP’s office and MAA as soon as possible to determine if there are any unique issues associated with the equipment (e.g., program income implications).

Including Mid-Year Equipment Purchases in annual proposal

When the purchase of a piece of equipment for the operation of a recharge/cost center (center) is expected to occur within a period covered by a rate schedule, that piece of equipment may be included in the depreciation schedule of the rate proposal.

For a future equipment purchase to be eligible for inclusion in a center rate proposal, the acquisition date and cost of the equipment should be known or accurately estimated.

The depreciation start date should be based on the anticipated acquisition date. This is usually the start of the quarter following the acquisition date of the equipment. Center rates cannot include depreciation for equipment for any period prior to the anticipated acquisition date. For example, if the center rate begins July 1^st and the anticipated in service placement of the new equipment is October 1^st, the center can only include 3 quarters, or 75%, of the annual depreciation for that year.

Mid-Year Equipment Purchases not included in annual proposal

When the purchase of a piece of equipment for the operation of a center occurs within a period covered by a rate schedule and that piece of equipment was not included on the depreciation schedule in the rate proposal, centers should update their depreciation schedule and determine whether a mid-year rate adjustment is needed.

If a mid-year rate adjustment is necessary, the center should submit an adjustment approval request to both their Dean/VP’s office and/or MAA highlighting the updated costs and the new depreciation schedule.
If a mid-year rate adjustment is not necessary, the center should submit the new depreciation schedule to their Dean/VP’s office and/or MAA notating that a new proposal is not necessary.

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