These guidelines are intended to provide clarification in defining, planning for and monitoring changes in level of effort or shifts in the source of funding for faculty effort commitments under sponsored agreements. Guidelines include changes in:
- effort charged directly to sponsored agreements
- cost sharing commitments
- funding shifts (i.e. changes in the source of salary funding)
- reductions of effort
The scenarios and examples below assume the award is under expanded authorities i.e. the University (typically the Office of Sponsored Programs [OSPii]) has designated authority to act on behalf of the Federal government (sponsor). If the award is not under expanded authorities, then sponsor approval is generally required prior to any actions being taken.
- The Federal government assumes the PI will generally maintain the originally proposed level of effort even when an award is reduced from the original funding requested.
- The "originally proposed effort" or "originally funded amount" is the percent against which future reductions should be determined and calculated.
- A renegotiated "originally proposed effort" or "originally funded amount" becomes a new percent/amount against which future reductions should be calculated.
While this document refers to the PI (out of writing convenience), a change in the level of effort of any Key Personnel (as identified in the proposal or the notice of award document) on a sponsored project requires that the same procedures be followed.
Under the guidelines in the "Uniform Administrative Requirements, Cost Principles, And Audit Requirements for Federal Awards" (Uniform Guidance) Title 2 CFR Chapter II, Part 200 (formerly Office of Management and Budgetii (OMi) Circular A-110ii), a PI or other key personnel may not reduce his/her cumulative maximum effort by 25% or more across all non-competing segments of the award without prior agency approval.
If, at any time, the cumulative change represents 25% or more reduction of the originally committed effort, a formal request for prior approval to the sponsor for the reduction in effort is required.
Note: this guidance applies only to Federal grants. Departments should check the specific terms and conditions for Federal contracts and non-Federally funded sponsored agreements.
Process for Documenting Reductions of Effort or Shifts in Funding Source
When there are changes either in the level of effort provided or shifts in the funding source(s) supporting the effort, the following procedures should be followed.
- Reduction of Effort from Original Commitment
- Less than 25%: adjust OPUS to reflect new percent effort.
- 25% or greater: contact sponsor through OSP for prior approval.
- Shift in Funding Source from Award Funds to Other Salary Sourcesi with no reduction in effort
- If the change is less than 6 months, use the Adjust/View Cost Share feature in eFECS Effort Reportingi to set up a "shift" cost share.
- If the change is 6 months or greater, or will impact more than one FEC cycle, the department must prepare a Cost Share Addendum and send it to GCAi with an informational copy to OSP.
- GCA will add the cost share commitment to the Cost Share Module.
- Ensures the cost share commitment appears on the FEC as a reminder to departments that a shift in the source of funding has occurred creating a cost share obligation.
It is recommended that, for the department's future reference, documentation for the shift in funding sources for the grant be maintained in department records (e.g. OPUS text, letter in faculty and/or grant file, etc.)