Our institution does not allow faculty to have 100% of their time funded on sponsored projects. There must always be a reasonable amount of effort covered by unrestricted sources for the reasons cited below. There may be research techs and other personnel that do spend 100% of their effort on a project, but a faculty member, by virtue of their professional position, would necessarily have other duties not related to a specific grant. Paula McCauley-Shelton, B.A. Grants Manager UAMS Department of Pediatrics Grants Administration MS 512-1 501-364-2368 Phone 501-364-4656 Fax xxxxxx@uams.edu *NEW* We've Moved! The Pediatric Grants Administration group is now located on the 3rd floor of the ACHRI Building. -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Carolyn Elliott-Farino Sent: Tuesday, December 01, 2009 3:08 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] lobbying certification Maybe, "Do you want to be on the front page of the newspaper?" I thought that you should never have anyone 100% on a grant, that 95% was a safer number, for precisely the reasons enumerated here: meetings, advising, emails -- there is always going to be something the person needs to do that is not directly related to the grant . It doesn't matter if the person writes one email to a congressman and it takes him 2 minutes; by virtue of the sending of that email, the person has demonstrated that they are not working 100% on the grant. CEF -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Charlie Hathaway Sent: Tuesday, December 01, 2009 3:49 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] lobbying certification What is this "front page of newspaper test"? So, what does effort (especially 100% effort) on federal projects mean? We have discussed some of this here before, i.e. how much of a scientist's time can be spent doing career and community development activities? Attending weekly departmental seminars (very often on topics completely unrelated to one's own work), serving on the thesis committee of someone who is not your student, preparing and giving a lecture, and...writing proposals for new projects. Geez...I didnt even include fixing the xerox machine or organizing the Christmas party. THUS...if this person is writing one letter or one email per week to the congressman, who cares? CH > > if you have to think about it for more than 30 secods- it is NOT able to > be billed to federal funding especially if the ultimate outcome is to > obtain federal funding for theogram/project. > > the front page of the newspaper test is also a good measure > > > > > -----Original Message----- > From: Gregory Schmidt <xxxxxx@VERIZON.NET> > To: xxxxxx@hrinet.org > Sent: Tue, Dec 1, 2009 2:53 pm > Subject: Re: [RESADM-L] lobbying certification > > > Hey, Charlie. > > I would think that if they're paid 100% on a federal project, they would > be spending 100% effort there. To spend time doing other things in an > official capacity, that 100% is being diluted with lobbying efforts. It > would be an official function as he is promoting his center to Senators, > Representatives, and sponsoring officials. This would make the PI's > effort reports false since you cannot perform more than 100% effort. > > The person's effort is paid 100% by the contract/grant. The person's act > of lobbying would mean that the sponsoring agency is in fact paying for > lobbying. Whether the individual is paid to lobby or not as a part of > their job function is irrelevant (to me at least). The fact is he is > lobbying and he's paid a salary which is reimbursed by the fed. That's > not legal. > > I understand why he's doing it. He's trying to keep his center alive in > tough times - a difficult endeavour in the best of times. It just doesn't > work for me. I would disallow it and a lot of the expenses (direct and > indirect) along with it. > > My take on it. > > Greg Schmidt > > GKS Consulting, LLC > 703-346-5696 > > > > This information is intended for the named recipient only and may contain > confidential/privileged material. Review, dissemination, or use of, or > reliance on this information by others is prohibited. If received in > error, please contact xxxxxx@verizon.net and delete. > > > Nov 30, 2009 04:43:10 PM, xxxxxx@hrinet.org wrote: > > To my mind there are 2 important words in the original question: > > "some": "spends SOME time organizing..." > > "for": "No federal appropriated funds have been paid...to any person > FOR influencing or attempting to influence an officer..." > > I'm guessing that this person does not spend much time "lobbying" (broadly > defined) and is probably not paid to lobby. > > So??? > > CH > >> That person cannot be paid 100% from federal funds. The percentage >> that they spend doing lobbying must be paid from general university >> funds and cannot become a part of the overhead. In addition, the >> overhead associated is also unallowable as are their benefits. It's a >> taboo cost that will cause a lot of questions. Because universities >> do not account for actual hours worked, calculating the percentage will >> be difficult to prove. They will make you prove the hours. This is >> why universities will hire someone specifically to do lobbying for them >> and identify a specific office for that activity - so there can be no >> questions. Good luck. You may need it. >> Greg Schmidt >> >> GKS Consulting, LLC >> 703-346-5696 >> >> >> >> This information is intended for the named recipient only and may >> contain >> confidential/privileged material. Review, dissemination, or use of, or >> reliance on this information by others is prohibited. If received in >> error, please contact xxxxxx@verizon.net and delete. >> >> >> Nov 30, 2009 12:57:52 PM, xxxxxx@hrinet.org wrote: >> We have a person on our campus who is paid 100% with federal funds. If >> that person spends some time organizing local support for his center >> and visits congressional aids to garner support for his center (with the >> ultimate goal of getting a federal contract) I believe we can no longer >> make the lobbying certification that states: >> >> No federal appropriated funds have been paid or will be paid, by or on >> behalf of the undersigned, to any person for influencing or attempting >> to >> influence an officer or employee of any agency, a Member of Congress, an >> officer or employee of Congress, or an employee of a Member of Congress >> in connection with the awarding of any federal contract, the making of >> any Federal grant, the making of any Federal loan, the entering into of >> any cooperative agreement, and the extension, continuation, renewal, >> amendment, or modification of any Federal contract, grant, loan, or >> cooperative agreement. >> >> However, another interpretation of this certification on our campus is >> that this only applies if we HIRE a person to perform lobbying >> services--but does not apply to a center director who is doing these >> activities "on his own time." >> All comments will be welcome. >> >> >> >> >> ====================================================================== >> Instructions on how to use the RESADM-L Mailing List, including >> subscription information and a web-searchable archive, are available via >> our web site at http://www.hrinet.org (click on "Listserv Lists") >> ====================================================================== >> ====================================================================== >> Instructions on how to use the RESADM-L Mailing List, including >> subscription information and a web-searchable archive, are available via >> our web site at http://www.hrinet.org (click on "Listserv Lists") >> ====================================================================== > > > ====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") > ====================================================================== > > ====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available via > our web site at http://www.hrinet.org (click on "Listserv Lists") > ====================================================================== > > > > ====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") > ====================================================================== > ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
