I have the following policy questions related to time and effort.

1. OMB Circular A-21 allows for a degree of tolerance for allocation of
costs and effort

 a. What tolerance thresholds does your Institution use for time and
effort?   I have seen many that use 5%.

 b. How is the tolerance threshold trained to staff?  For example if
a time end effort report lists the PI effort at 25% and the PI believes
their effort is 25-30% would you have the PI change the effort listed or
leave it unchanged as it is within a 5% tolerance?

 c. If a time and effort report for a research tech or a PI has
payroll at 100% charged to a grant but the research tech/PI knows that
their effort for the time period was only 97% to the grant and 3% was
administrative time is it your policy to correct the payroll charged to
97% or is the 3% variance within the threshold and therefore no
correction is made?

2. Do you have a policy regarding the maximum amount of effort that can
be charged to a sponsored project for faculty members or any group of
employees?

3. Does your effort reporting apply to both Federal, (including federal
pass through) and non-federal sponsored projects or only Federal?

4. Under what circumstances do you allow changes to be made to the
certification of effort form after it has been certified?

Thank you for your help

Kim Babbie
(518) 262-5496

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