This policy describes the minimum effort required for principal investigators (PIs) and key personnel on sponsored programs projects.
Effective January 5, 2001 through a Presidential Review Directive and clarification memo M-01-06 issued by the Office of Management and Budget (OMB), it is expected that “most 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).” The clarification memo also states that, “...Some types of research programs...do not require committed faculty effort, paid or unpaid by the Federal government...”
Further, the National Institutes of Health (NIH) Grants Policy Statement notes that “zero percent” effort or “as needed effort” is not an acceptable level of involvement for key personnel.
Therefore, in preparing proposals and in allocating effort after award, all PIs and key personnel must include some level of committed effort on most sponsored research activities. Some exclusions apply (see EXCLUSIONS below); however, programs that do not cover key personnel salary expenses do not qualify as an exclusion (instead, effort must be cost shared). Any effort devoted by these individuals that is above the committed effort amount is considered uncommitted effort. Other contributing personnel must be included in the proposal reflecting their effort contributions to the project.
PIs must quantify effort commitments (e.g., a percentage of time, dollar amount of salary, number of months, etc.) in the proposal. These commitments are paid from (1) the sponsor and/or (2) other, non-federal VCU sources. The effort commitments must be fulfilled within each year (summer months, academic year, or both).
The minimum amount of effort committed to a specific sponsored research activity may be no less than 1 percent of the key personnel’s university effort. Beyond this minimum, the specific amount of effort committed to a particular sponsored activity is left to the judgment of the principal investigator/program director, based on their estimate of the effort necessary to meet the technical goals and outcomes of the project.
Some federal and federal flow-through sponsored programs do not require a minimum level of committed effort by PIs and key personnel and therefore are not subject to this policy. The following are excluded from the requirements set forth in this policy:
(This listing is not all-inclusive: Should you have questions about a particular program or sponsored activity, please contact your school/departmental research administrator or the Office of Sponsored Programs for further guidance. Please also see the note below.)
Note: Consult the sponsor’s specific program terms and conditions for the presence of required effort commitments. If minimum effort commitments are required by the sponsor’s program terms, the program specific terms take precedence over the program or sponsored activity exclusions listed above.
Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.
All individuals involved in sponsored programs are responsible for knowing this policy and familiarizing themselves with its contents and provisions.
Any part of university effort that is quantified and included in a sponsored program proposal and the subsequent award (e.g., two summer months, 12 percent time, one half of a year, three person-months, etc.). This quantified effort/time is associated with a specific dollar amount of the employee’s compensation. Associated effort and funding to support this devoted effort/time can be in the form of direct charged effort or cost shared effort.
Cost Shared Effort
Any portion of university effort toward a sponsored activity for which the sponsor does not pay salary/benefits, but instead are paid using other non-federal VCU sources.
Direct Charged Effort
Any portion of university effort toward a sponsored activity for which the sponsor pays salary/benefits.
Individuals who provide critical leadership positions within the proposal (and consequently their intellectual guidance) or who provide unique expertise to the proposed scope of activity. Key personnel typically include principal investigators, research scientists, principal scientists and senior scientists, depending on their intellectual contribution to the proposed scope of activity. Typically, replacement of any of these individuals requires approval from the sponsor. Importantly, the status of key personnel does not necessarily imply salary support from the sponsor.
Individuals who provide critical leadership positions within the proposal (and consequently their intellectual guidance) or who provide unique expertise to the proposed scope of activity. PIs also administratively manage the sponsored program. Typically, replacement of any of these individuals requires approval from the sponsor. Importantly, the status of principal investigator does not necessarily imply salary support from the sponsor.
An externally funded program under which the university is obligated to perform a defined scope of work according to specific terms and conditions and within budgetary limitations. These programs are to be budgeted and accounted for separately from other activities. Sponsored programs include grants, contracts, cooperative agreements, clinical trial agreements, Intergovernmental Personnel Agreements and other awarding instruments supporting research, instruction, public service, and clinical trials.
Any portion of university effort devoted to a sponsored activity that is above the amount committed in the proposal and the subsequent award. This ‘extra’ effort is neither pledged explicitly in the proposal nor included in the award documentation as a formal commitment.
The sum of all activities at Virginia Commonwealth University, for which the employee is compensated (through VCU and MCVP). This includes research, instruction, public service/other sponsored programs, administration and clinical activities. For the purpose of effort certification, university effort totals 100 percent, regardless of the number of hours worked. University effort does not include Veterans Administration compensation.
The Office of Sponsored Programs officially interprets this policy. The Office of Sponsored Programs is responsible for obtaining approval for any revisions as required by the Policy on Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to the associate vice president for sponsored programs.
The following offices and positions have roles and responsibilities in the documentation, recording and monitoring of minimum effort for sponsored programs.
The Office of Sponsored Programs is responsible for:
There are no forms associated with this policy and procedures.
This policy supersedes the following archived policies:
|10/22/2012||Minimum Effort for Key Personnel on Sponsored Programs|
|03/19/2015||Minimum Effort for Key Personnel on Sponsored Programs|
|01/12/2018||Minimum Effort for Principal Investigators and Key Personnel on Sponsored Programs [12/13/2019 – minor revision to repair typographical error]|