Reductions in Level of Effort or Changes (Shift) in Source Funding for Committed Effort

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 notice of award document) on a sponsored project requires that the same procedures be followed.

 

Federal Requirements

Under the guidelines in CFR Title 2,Subtitle A, Chapter II,  Part 215, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (formerly Office of Management and Budgetii (OMBii) Circular A-110ii), a PI 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 Awardi 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.)

 

Scenario

  • Faculty indicates 20% effort commitment on a grant proposal.
  • After the proposal is awarded, the PI discovers a need to reduce his/her effort to 16% (a reduction which is less than 25% of the originally proposed effort).

Shift Calculation: (20% - 16%) ÷20% = 20% change in effort

 

Option #1: Original effort is directly charged to the grant:
  • Department Action: The PI directs the department to make appropriate adjustments to OPUS to reduce the salary charged to the grant commensurate with the reduction in the level of his/her effort.
  • No other action is required as change is less than 25%.

 

Option #2: Original effort is cost shared (short or long term)
  • Department Action: Department submits a Cost Share Addendum directly to GCAi to reduce the cost share pledge in the Cost Share Module for the PI.
  • GCA Action: GCA reduces the pledge as documented by the revised Cost Share Addendum.

 

Option #3: Original effort is cost shared and some responsibilities are assumed by another faculty member (short or long term)
  • Department Action: Department secures appropriate approvals for commitment of funds to cost share salary of another faculty member.
  • Department Action: Department submits a revised Cost Share Addendum directly to GCA to reduce the cost share pledge in the Cost Share Module for the PI. If the team member assuming the additional responsibility is not being paid from the grant for the additional effort, then the cost share for that team member should be included with information added to the revised Cost Share Addendum.
  • GCA Action: GCA reduces the original pledge as documented and also adjusts the pledge by adding the faculty member replacing the PI if documented on the revised Cost Share Addendum.

 

Note: If the originally documented cost share is Mandatory, i.e., required as a condition of the award, other cost shared expenses must be provided to make up any shortfall resulting from the adjustments to PI or other personnel effort.

 

Scenario

  • Faculty indicates 20% effort commitment on a grant proposal.
  • After the proposal is awarded, the PI discovers a need to reduce his/her effort to 10% (a reduction which is 25% or more of the originally proposed effort).

Shift Calculation: (20% - 10%)/20% = 50% change in effort

 

Option #1: Short term

Department Action: Department determines if additional effort during subsequent cycles and/or effort from previous cycles,  will result in a total change in effort of less than 25% (within competitive grant periods). If this is true, then no action is required beyond adjusting OPUS. (See Example 1, Option 1).

 

Option #2: Long Term – When Directly Charged to Grant
  • PI Action: PI must forward a written request to OSPi for their concurrence and submission to the sponsor's Grants Management Officer (GMO).
  • PI/Department Action: Wait for Sponsori approval.
  • When written approval is received from the Sponsor
  • OSP Action: OSP will forward approval to PI and Department
  • Department Action: The PI will direct the Department to make appropriate changes in OPUS to reduce the salary charged to the grant commensurate with the reduction in the level of effort.

Note: All Federal grants and some non-federal grants require sponsor approval. Departments should check with OSP if there is any question about the sponsor’s requirements.

 

Option #3: Long Term – When Effort is Cost Shared
  1. PI/Department Action: PI must forward a written request to OSP for their concurrence and submission to the sponsor's GMO
  • PI/Department Action: Wait for Sponsor approval.
  • Sponsor Action: Written approval is received from the Sponsor
  • OSP Action: OSP will forward approval to PI and Department and will send a revised Post Awardi Change (PAC) and revised Cost Share Addendum to GCAi.
  • PI/Department Action: The PI will direct the Department to make appropriate changes in OPUS to reduce the salary charged to the grant commensurate withe the reduction in the level of effort.
  • GCA Action: GCA adjusts the cost share pledge in the Cost Share Module.

 

Note: All Federal grants and some non-federal grants require sponsor approval. Departments should check with OSP if there is any question about the sponsor’s requirements.

A change in effort which requires sponsor approval should not be initiated until AFTER the formal approval is received.

Scenario

  • Faculty indicates 20% effort commitment 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 (e.g., from 20% to 15% from the award) but maintains his/her effort committed at the originally proposed level of 20%.
  • This results in a cost share situation

 

Option #1: Short Term (6 months or less):

Note: A Cost Share Addendum is NOT required for this scenario

  • Department Action: Choose "Edit Comments" on the FEC and in the "Additional Comments" section, place a notation in the comment box confirming the proposed pledge X% of committed effort for this faculty member remains the same and that this is a short term shift in funding source.
  • Department Action:
    • Click on the "Adjust/View Cost Share" button on the FEC
    • Choose "Add Item"
    • Enter the budget number and choose "Short Term Shift" cost share type
    • The percent entered will normally equal the difference between the amount pledged in the proposal and the amount charged directly to the grant
  • MAAi Action:

    • MAA assumes the faculty member signing the FEC has received concurrence from the department chair (or authorized department representative) to commit departmental resources for meeting this newly created cost sharing amount.

    •  MAA will periodically sample this type of cost shared effort to ensure the department is not over cost sharing or accounting for voluntary uncommitted effort as cost sharing and that it is of a short term nature.

 

Option #2: Long term (6 months or greater): originating at receipt of grant OR for more than one cycle.
  • Department Action: The department prepares a Cost Share Addendum documenting amount of effort being cost shared.
  • Department Action: Sends the Cost Share Addendum  to both OSPi (for information purposes only) and GCAi for entry into the Cost Share Module.
    •   Submit Cost Share Addendum revised prior to certification of the FEC to avoid need to recertify.
    • Choose "Edit Comments" on the FEC and in "Additional Comments" section, placing a notation in the  comment box confirming that the proposed pledged X% amount of committed effort for this faculty member is unchanged and that this is a long term shift in funding source.
  • Department Action: The dean’s or department chair’s signature (or their designee) must appear on the Cost Share Addendum to ensure that appropriate permissions have been obtained and resources are available.
  • GCA Action: GCA will set up an “S” (Shift in Funding Source) cost share pledge in the Cost Share Module. This pledge will then be displayed on the FEC form.
  • Department Action: Cost sharing must be met before the budget can close. Note: if the department does not complete and submit the Cost Share Addendum, the pledge will not appear on the FEC.
  • Department Action: Should the PI decide to begin charging his/her full effort at a later date, an updated Cost Share Addendum must be filed in the same manner to discontinue this expectation of cost sharing.

Note: While GCA does not report "Shift" cost share to the sponsor, it is expected that the cost share will be met before closing the budget as it documnets the committed effort for the PI or key personnel.

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