Faculty Effort on Sponsored Research - FAQS
General Effort FAQS
1. I am submitting a proposal for a sponsored research project. How much effort should I propose?
Proposals should represent the effort that key personnel expect to commit to the project.
2. Do I still need to charge or cost share effort during every active quarter of an award?
No, you are no longer required to charge or cost share effort in every active quarter of an award. However, some effort needs to be direct charged or cost shared during each year of the period of performance. This effort can be provided at any time within the year (summer months, academic year, or both). However, salary may not be direct charged if no effort is expended. It is the responsibility of the PI and department to track committed effort during the performance period of the award to ensure the original effort commitment to the sponsor has been met. The School of Medicine requires approval for any cost sharing of faculty effort/salary. (http://med.stanford.edu/rmg/facultyeffort.html)
3. What if I have a breakthrough on my project and I spend more time than originally proposed? Do I need to track the additional time that I spend on my project?
No. You do not need to track the voluntary uncommitted effort that you may spend on your project. You do NOT need to direct charge or cost share this incremental effort.
4. What do I do if the proposed effort needs to be changed at the time of award or later during the award?
Effort may need to be reduced at the time of award as a result of reduced funding and/or scope of work or because there is a change in the amount of effort available to devote to the project. If the effort needs to be reduced by 25% or more, you may need to obtain prior approval from the sponsor. Please check with your institutional representative (Office of Sponsored Research [OSR] or Research Management Group [RMG]) to determine if prior approval from the sponsor is required and the steps required to request approval.
5. Does the effort policy apply to only the PI or also to co-PIs?
This policy applies to PIs and co-PIs.
6. I am a PI on an Industry-Sponsored Clinical Trial. Do I need to charge or cost share effort in every period of the award?
PI effort expended on Industry-Sponsored Clinical Trials is dependent on the patient enrollment and when the patient procedures are performed. PI effort is not required for those periods where there is no activity on the study and procedures on patients have not been performed.
7. I am a PI on an award, but I am on sabbatical. Must I charge salary for my effort committed to that period?
No, you do not need to charge effort directly to the project because there is an expectation that your sabbatical time may be used for research purposes. When a faculty member is on sabbatical his/her salary is paid from the sabbatical pool that is funded from the negotiated fringe benefit rate. However, if your sabbatical pay is part time (less than 100%) and you plan to devote your non-sabbatical time to your sponsored awards, you may continue to charge your salary directly to a sponsored project(s).
8. I am an emeritus faculty member serving as PI on a sponsored research project. Are there special requirements I should keep in mind?
Emeritus faculty must be recalled to active duty with the approval of their primary department for the period for which the award is active. Emeritus faculty may or may not receive compensation for their work on sponsored projects. Emeritus faculty receiving compensation must be placed back on Stanford payroll with the pay rate set by the school or department prior to returning to Stanford. The emeritus PI may have a part-time appointment representing only their percent of effort on the sponsored award. Emeritus faculty not receiving compensation may donate their time to the award. This requires no direct charge or cost sharing to the sponsored award.
9. Is PI effort required during a no-cost extension period?
Some federal agencies require some level of effort during a no-cost extension period. When submitting a request for a no-cost extension, state the level of effort for all key personnel for the no-cost extension period. No-cost extension periods are typically granted for a 12 month period or longer. It is important to notify the sponsor if the work is completed before the extended end date to request a revision to the extension period so the award can be closed and to avoid a cost-sharing commitment for the remainder of the original extended period.
10. I have a nine-month faculty appointment. I wish to donate my time during the summer to my project without compensation from the award or a departmental fund. Am I required to charge the award or cost share effort?
No. However, some effort needs to be direct charged or cost shared during each year of the period of performance.
11. Are there any exceptions to the requirement for commitment of PI effort? If so, what are they?
The requirement for PI effort does not extend to:
- Equipment grants
- Seed grants for students/postdocs where the faculty mentor is named as PI, dissertation support, training grants, or other awards intended as "student augmentation."
- Limited-purpose awards characterized by Stanford as Other Sponsored Activities, including travel grants, conference support, etc. (see Categories of Sponsored Projects, Research Policy Handbook 13.2, for definition and further examples of Other Sponsored Activities.)
12. What is a “student augmentation” award? Do I need to charge or cost share PI effort on this type of award?
A student augmentation award is an award whose primary purpose is to fund a student’s or post doc’s activity. You do not need to include committed PI effort in the proposal nor do you need to charge or cost share PI effort.
13. What about research-only faculty on 12-month appointments? Do they have a limit on the amount of time spent on research?
The various schools may have their own policies, but typically research-only faculty may charge up to 95% of their effort on research. Check with your school for their policy, which will apply to all 12 months of the appointment.
14. Can the PI donate time to an NSF project and not request salary support?
No. That would be considered cost sharing of project expenses, and NSF prohibits cost sharing, unless otherwise specified in the solicitation. Additionally, Stanford policy requires a commitment of effort on the part of the Principal Investigator during the period in which the work is being performed. This effort may be expended during the academic year, summer quarter only, or both.
Exceptions to the requirement for the commitment of PI effort are shown in the response to Question #11, above.
Summer Salary for Faculty on Nine-Month Academic Appointments
1. Are the issues that led to the change in summer salary policy unique to Stanford?
No. These issues impact all institutions that have faculty on nine-month appointments and allow summer or off-duty quarter compensation in addition to academic year salary.
2. Can I charge effort during the academic year to my NSF award?
NSF clarified their policy on academic year effort in October 2008, stating effort may be charged during the academic year to the award. In general, NSF limits salary compensation for senior project personnel to no more than two months of their regular salary from all NSF sources in any one year. A third month may be allowed on an exception basis when approved by NSF. (See response to question 3 below.)
3. I have already been funded for two NSF summer months. May I request support for senior personnel in excess of two summer months?
Yes, the NSF Grant Proposal Guide states the following. “As a general policy, NSF limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with the applicable cost principles. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget.” You may contact your program officer prior to submitting the proposal
4. May I charge more than two months of salary to an NSF award?
Yes, the NSF Grant Proposal Guide (January 2016) states:
“under normal rebudgeting authority, as described in AAG Chapters II and V, an awardee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long as that change would not cause the objectives or scope of the project to change.NSF prior approval is necessary if the objectives or scope of the project change.”
Please review the Terms and Conditions of your award to verify that re-budgeting is applicable to your grant. The rebudgeting policy can be found in the Proposal & Award Policies & Procedures Guide (PAPPG).
- For guidance on proposals submitted or due after January 25, 2016, and awards made after January 25, 2016, continue to reference the PAPPG (NSF 16-1) dated December 26, 2016 (NSF 16-1).
- For guidance on proposals submitted or due before January 25, 2016, and awards made before January 25, 2016, continue to reference the PAPPG (NSF 15-1) dated December 26, 2014.
5. My proposal only requested salary for summer months. Am I required to charge effort during the academic year?
No. Effort may be charged within the fiscal year (summer months, academic year, or both). However, salary may be charged only up to 90% in each of the summer months, commensurate with effort expended. Any remaining effort may be charged during the academic year commensurate with effort expended.
6. How will the summer salary policy be implemented?
Each School Dean will determine how to implement this policy for his or her school. The following is an example of implementation: - Up to a total of 90% of a full one ninth of academic salary can be charged to federal and non-federal sponsored projects during the summer, commensurate with effort. - During the academic year, effort should be charged as it is incurred. NSF now allows charging sponsored projects during the academic year, and effort should be charged at the time it is expended. If there are salary savings that accrue to departments during the academic year, they can be used to support academic effort during the summer (or off-duty) quarter.
7. What if I only have one or two months of summer salary support?
If you only have one month of summer salary support, you may spread the salary over two or three summer months, if the work is being performed over that period of time. If you have two months of summer salary support you may spread the salary over three summer months, if the work is being performed over that period of time.
8. What do I do if the grant is already underway and I have budgeted 100% effort for one summer month?
You will need to revise the budget. The faculty member’s salary can be charged in the summer month commensurate with the effort devoted, up to a maximum of 90%. Any remaining effort may be charged during the academic year commensurate with effort.
9. Am I limited to 90% salary during the summer months?
No. You can still receive 100% salary during one to three summer months by supplementing sponsored funds with other fund sources. (See response to question 4 above.)
10. I’m a faculty member on a nine-month appointment. During the summer months, I plan to devote effort to an NIH grant. My academic year salary is over the DHHS salary cap rate. Do I still have to account for over-the-cap salary during the summer?
The DHHS salary cap is in effect all year, including the summer months. During the summer months, there are two options:
- You may elect to be paid at the DHHS salary cap level during the summer months. If you are working on other sponsored projects during the summer months, you must charge all sponsors, and all sponsored projects, at the same rate of pay. Charging different rates of pay would create inconsistent treatment of salary charged to each sponsor.
- Provided you have sufficient non-sponsored funds and wish to be paid at your academic year rate during the summer months, you must charge any over-the-cap salary to the non-sponsored PTA(s) using the salary cap Expenditure Type (ET 51190).
10. I have a nine-month appointment. How can I tell if my salary is over the DHHS salary cap?
Divide your salary by 9 and multiply it by 12 to get your annualized rate of pay. If this amount is greater than the current DHHS salary cap, then you must capture the difference on the "over the salary cap" expenditure type. Conversely, you can take the current salary cap amount, divide by 12 and multiply by 9. If your 9 month salary is greater than the result, you must capture the difference on the "over the salary cap" expenditure type. See NIH(DHHS) Salary Cap
Note: NIH is one of many DHHS agencies (others include SAMSA, CDC, AHRQ)