Federal policy regarding effort of principal investigators and other key personnel requires us to identify effort committed to federal projects and then monitor for changes.
UC Davis uses an electronic Effort Commitment system to record commitment levels and then uses this information to compare to actual effort, both charged and cost shared.
CGA is capturing information in the Effort Commitment System
Principal Investigator Effort
- For all federal and federal flow-through awards, CGA enters the commitment level identified in the award contract.
- If there is no commitment of effort in the award contract, minimum effort may still be required. UCD policy (PPM 330-31) addresses research awards as required by OMB Memo 01-06.
- Some level of effort must be entered for all federal/FFT research awards.
- For non-research (e.g., public service, training, etc.) federal funding only enter a commitment if it is identified in the award document.
Key Personnel Effort
- Effective 9/18/2017, for all federal and federal flow-through awards, CGA enters the commitment level identified in the award document.
- Commitments are entered for anyone listed by name (not TBD) in the award as key personnel.
- Some agencies (e.g. NIH) may include a “key personnel” section in the award
- Some budgets use a key personnel category
- Commitments are entered for anyone listed by name (not TBD) in the award as key personnel.
- CGA considers “Co-Principal Investigator” and “Co-Investigator” as key personnel and enters commitment level.
Monitoring Effort Commitments
- There will be a quarterly review process beginning in January 2018, for the quarter ended 12/31/2017.
- CGA’s compliance team will review federal effort commitment entries where the budget year ended during quarter under review.
- The query will determine whether any payroll or cost share has been recorded for identified key personnel (including PI) in the sample.
- Departments will be sent a list of commitments where the percentage of payroll charges plus cost share for the budget year is 0% or significantly less (>25% reduction) than the effort commitment.
- A letter will be sent to the fiscal officer on a sample of those funds, requesting information on how they plan to meet the commitment (e.g. summer salary will be charged in June 2018), or a copy of the sponsor approval for a reduction or change of key personnel can be provided.
- On the CGA side, this process is similar to the review of PI minimum effort conducted as part of the annual Effort Certification process. However, there will be no way to accommodate exemptions based on the type of award, since this review is looking only at effort committed to the sponsoring agency in the award contract. Timing differences will be allowed as long as there is sufficient time left in the award period to meet the commitment. For example, if the department plans to charge summer salary in June 2018, the award period must end on or after June 30, 2018.