PrintBackground
FAS faculty members spend much of their time during the academic year conducting, and directing others conducting, research on projects supported in large measure by external sponsors. When faculty offer explicitly to devote a definite portion of their effort to a project (in the narrative, budget, or budget justification of a proposal), at no cost to the sponsor, that offer constitutes a voluntary commitment by the University to share project costs. The commitment is binding if the award is granted. Significant commitments inappropriately limit the freedom and flexibility that University salaries are intended to provide, and increase the need to maintain extensive records subject to detailed audit. Significant commitments of effort also place a financial burden on the Faculty, which is responsible for the associated indirect costs. Investigators should therefore minimize the amount of uncompensated effort they commit explicitly in grant proposals. Any such commitments must undergo review.
Obviously, this warning should in no way be construed as encouraging faculty members to devote less effort to their research, or to report incompletely or inaccurately on their explicit commitments. We simply want you to be aware of the consequences of cost sharing and the burden that it creates.
Procedure
You must check the box for "Cost Sharing/Faculty Contributed Effort" on the Dean's Approval Form of any proposal whose narrative, budget, or budget justification includes an explicit quantifiable commitment of faculty effort not charged to the sponsor. Page 2 of the Dean's Approval Form includes a space to indicate the amount of effort committed in the proposal and the reason for the commitment. Uncompensated effort commitments must be approved by FAS Research Administration Services prior to proposal submission, which may increase the amount of time required for proposal review.
Some program announcements mandate a certain level of PI effort or other cost sharing. Explanation of any mandatory contributions should be included on Page 2 of the Dean's Approval Form, and a Cost Sharing form attached. The Dean's Office will continue to work with PIs and departments to satisfy mandated cost sharing requirements, as has been the case in the past.
Suggestions for proposal narratives
General statements in the narrative or budget justification of the proposal can indicate the PI's intention to participate significantly in the research without creating a contractual and auditable quantified commitment of effort:
Professor X will direct all research activities associated with the project [specify...]
Professor X will oversee [all aspects of] the project.
Professor X will participate in the project at every stage [specify...]
Professor X will provide scientific direction and supervision for the project [including...]
The following wording can also be used in conjunction with statements such as the above, where appropriate:
The University pays salary to full-time faculty members in the FAS based on a nine-month academic year, with the understanding that they will ordinarily teach and conduct research freely and flexibly and not make substantial, specific quantified cost-sharing commitments of time and effort to specific organized research projects. If allowed by outside sponsors, faculty members may request "supplemental salary" from sponsored funds up to the equivalent of three months' compensation.
Alternatively, some investigators have chosen to describe the nature of their participation--still without specifying a quantifiable commitment of effort--in greater detail, with language such as...
The Principal Investigator will be responsible for the overall planning of the projects, defining experimental directions, interpreting data, communicating with collaborators, and reporting project results to the sponsor and the scientific community in the form of progress reports, papers, and presentations. In addition, the PI will be responsible for mentoring participating student researchers.
Such language is also acceptable, so long as it accurately reflects the PI's intentions and does not propose a quantifiable commitment of uncompensated effort.
Current and Pending Support
The Office of Management and Budget (OMB) recognizes that estimates of the effort that will be spent on pending proposals in statements on the "Current and Pending Support" pages of a proposal are not binding commitments on successful proposals. However, the estimate of the level of effort that will be expended on each currently funded proposal should be consistent with the specific level of commitment in the budget and narrative of that proposal.
Agency-specific information
Since FAS policy is to avoid making quantifiable effort commitments in proposals unless salary is being paid by the sponsor, the level of PI committed effort should ordinarily reflect only salary actually to be paid from the grant. Under the FAS Supplemental Salary policy, a PI requesting three months of salary from a grant would indicate three person-months of calendar-year (CY) effort commitment, and a postdoctoral fellow working full-time on a grant would indicate twelve person-months of calendar-year (CY) commitment.
- NSF: Except in programs with specific requirements, the National Science Foundation does not expect the PI to indicate the level of effort in the budget or budget justification when no salary is requested. In addition, per a June 1999 NSF directive, cost sharing (including voluntary contributed effort) cannot be used as a review criterion except where mandated by the program announcement. Where appropriate, investigators should use the kind of wording suggested above to indicate their intention to contribute extensively to the proposed project. Commitments of effort should, of course, reflect PI requests for supplemental salary (up to two months of salary may be paid by NSF).
- NIH: Applications on Form 398, and NIH Modular Grant applications, request information about the person-months of effort committed to the grant for all key personnel listed on the proposal and affiliated with the institution, regardless of salary source for their effort. Individuals listed as key personnel requesting no salary support (e.g., faculty whose supplemental salary (if any) is to be paid by other sponsored awards, or postdocs with their own fellowship support), must still indicate a non-zero effort commitment on the NIH budget pages. In such cases, faculty and research staff should indicate a commitment of 0.1 calendar-year (CY) person-months and clarify this commitment with language as indicated above.
- NASA, DoE, and DOD Agencies. Sources and level of support must be listed but no commitment of effort is required.
Questions
If you have questions about the commitment of effort on sponsored research proposals, or the review process, you should speak to your Laboratory Director, or Elizabeth Lennox (elennox@fas.harvard.edu, 6-2491), or Pamela Baker-Webber (bakerwebber@fas.harvard.edu, 5-9840).
