What about the effort commitments we make in NIH proposals and during the JIT process?

Because of NIH's way of doing business, we must provide measured levels of efforts using person months at the proposal stage, JIT stage and in Progress Reports.

At the JIT stage, a PI will create a value for Academic Year Time (i.e. time that is not being paid for on a grant, but a university source) even for grants for which we not create an effort calculation in a proposal (mainly non-Federal fund sources).

I don't think NIH thinks that what we are providing them is cost-share, but an allocation of time spent on research. An institution, however, might view this "committed effort" as "cost-share."

What I really struggle with are different agency standards and a research administration culture where don't really have standard definitions. I think we're using a lot of similar terms when discussing this issue that mean a lot of different things to different institutions and agencies.

On Jun 20, 2007, at 12:44 PM, Theresa Defino wrote:

In a message dated 6/20/07 3:14:18 PM, xxxxxx@CSUEASTBAY.EDU writes:

Dear colleagues,

I am at a Primarily Undergraduate Institution, where we are trying to clarify our policy on effort reporting. I would greatly appreciate your advice on the following question. If a faculty member is providing voluntary, non-committed effort to the project (e.g. the PI has not budgeted any funds for his/her time, and no mention is made explicitly of the time being cost-shared), do you have an internal policy to ask them to estimate their effort? The OMB guidance does not require reporting of such voluntary, non-committed effort; however, as we think about how we can verify that people stay under 100%, it seems that we should be collecting this information.

Thanks for your advice!

Sincerely,

Victoria Jensen
Interim Director
Office of Research and Sponsored Programs
California State University, East Bay

Be careful that it truly is not reportable time. NSF's OIG just dinged Caltech big time on this issue. I wrote an article about it in my June issue if you would like a copy.

Kind regards,
Theresa Defino
Editor
AIS Report on Research Compliance
www.reportonresearchcompliance.com
xxxxxx@aol.com
301.738.3721

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