Effort reporting total professional activity vs institutional activity
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Effort Reporting: Total Professional Activity vs. Institutional Activity. Salary and Wage Costs What NIH Expects. Charges for salaries and wages will reflect actual effort expended--not necessarily the proposed or budgeted effort

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Effort Reporting: Total Professional Activity vs. Institutional Activity

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Effort Reporting:Total Professional Activity vs.Institutional Activity


Salary and Wage CostsWhat NIH Expects

  • Charges for salaries and wages will reflect actual effort expended--not necessarily the proposed or budgeted effort

  • Charges for salaries and wages, whether treated as direct costs or indirect costs, will be based on documented payrolls/effort reports approved by a responsible official of the organization

  • Significant changes in actual effort vs. budgeted effort will be adjusted


What is a Significant Change?

  • No precise definition

  • Determination should be made by the employee or the individual who certifies the effort report

  • Any changes made by the individual or certifying official should be considered significant


Significant Change

  • General Rule: A change applicable to a given project or activity of 5% or more of an employee’s TOTAL effort would require an adjustment to the effort report


Salary and Wage Costs- Cost Transfers

  • Used to correct errors or changes in effort certified vs. budgeted effort

  • Must be well documented

  • Must be made in a timely manner


Personnel - Prior Approval

  • Required for change in a key person specified on Notice of Grant Award (NGA) Always Principal Investigator (PI)

    • Key Person: an individual identified in the application who contributes to the scientific development or execution of the project in a substantive way, whether or not salary is requested


Personnel - Prior Approval

  • Required if PI or other key personnel named on the NGA will:

    • Withdraw from the project completely

    • Be absent 3 months or more

    • Reduce time devoted to project by 25% or more


Prior Approval

  • Required for: Change in scope or objective of a project

    Change in Scope is a change in direction or other area that constitutes a significant change from the aims, objective, or purpose of the originally approved project (significant change in effort by key personnel could indicate potential change in scope)


Institutional Base Salary (IBS)

  • The annual compensation that the applicant organization pays for an employee’s appointment whether that individual’s time is spent on research, teaching, patient care or other activities.

  • Excludes any income that an individual may be permitted to earn outside of duties to the applicant organization.

  • May NOT be increased as a result of replacing institutional salary funds with grant funds


Revised NIH Grants Policy Statement


NIH Grants Policy Statement – A Closer Look

  • Closely related work:

    • NIH eliminated the option for grantees to pursue prior approval to account for multiple projects under a single cost objective

    • NIH applies the relatedness provision of A-21 to all NIH recipients, which is consistent with the FDP Terms and Conditions


NIH Grants Policy Statement – A Closer Look

Key Personnel:

  • Expanded definition to:

    describe contribution of key personnel as “measurable” whether or not salaries are requested.

    Clinical Practice Plan (IBS):

  • Clinical practice plan appointments compensation may be considered in the base salary as long as criteria are met.


Revised Grants Policy Statement

Clinical Practice Compensation (IBS):

Clinical Practice Compensation (CPC) appointments compensation may be considered in the IBS, provided:

  • CPC must be guaranteed by the university/Institution

  • Clinical practice effort must be shown on the appointment form and must be paid through the university/institution

  • Clinical practice effort must be included and accounted for on the university/institution effort report


Total Professional Activities – Other Support

  • NIH requires complete and up-to-date other support information before an award can be made

    • Complete means all sources of research support (including outside the applicant organization – Total Professional Activities)

  • Grantees must report changes in other support as part of the annual progress report

    NIH Guide, February 13, 2003

    http://grants.nih.gov/grants/guide/notice-files/NOT-OD-03-029.html


Total Professional Activities -Career Awards

  • Most Career Awards require a minimum commitment of total professional effort to research.

    • Previously defined total professional effort as all sources of research support (including appointments outside the applicant organization, exclusive of consulting activity within institution's limits.)

    • Effective for all applications submitted after 10/1/04 investigators will meet the required commitment of total professional effort as long as: 1) the individual has a full-time appointment with the applicant organization; and 2) the minimum percentage of the candidate’s commitment required for the proposed Career award experience is covered by that appointment.

      NIH Guide, August 3, 2004

      http://grants.nih.gov/grants/guide/notice-files/NOT-OD-04-056.html


Support/Commitment Overlap

  • Overlap of support (scientific or budgetary) is unallowable

  • Over commitment of an individual’s effort is unallowable


Salary Cap

  • Restricts the amount of direct salary under a grant or contract to Executive Level I of the Federal Executive Pay Scale

  • Executive Level I increase effective January 1, 2005

$180,100

$175,700

January 7, 2005 NIH Guide Notice

http://grants.nih.gov/grants/guide/notice-files/NOT-OD-05-024.html


Top 10 Issues on Salary Costs to NIH Grants?

  • Certifying official does not have first-hand knowledge of effort performed

  • Effort reports not certified and returned in a timely manner

  • Certifying the budgeted effort vs. actual effort

  • Salary cap not treated correctly with respect to effort and charging NIH grants/contracts

  • Corrections for significant changes in budgeted vs. actual effort are not made OR not made in a timely manner


Top 10 Issues on Salary Costs to NIH Grants?

  • Transferring costs from one project to another to avoid a cost overrun

  • Failure to get prior approval for change in key personnel, i.e., withdraw from project completely, be absent for 3 months or more or reduces time by 25% or more

  • Overlap of support (scientific or budgetary)

  • Overlap of commitment

  • Use of incorrect IBS, especially when CPC is involved


What’s at Risk?

  • Audit Findings/Cost Disallowances

  • Designation as High Risk Organization

  • Special Terms and Conditions on NGAs

  • Requirement for Corrective Action Plan

  • Special Monitoring by NIH

  • Temporary Withholding of Payments

  • Withholding of Future Awards


Questions?Joe EllisActing Director, Office of Policy for Extramural Research [email protected]


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