FAS Research Administration Services

Memorandum

To: Faculty Investigators in the Faculty of Arts and Sciences

From: Dean Jeremy R. Knowles

Subject: Commitment of Effort in Sponsored Research Proposals

Date: July 23, 2001

Investigators are often asked to estimate in grant proposals how much time or effort they plan to spend on sponsored projects during the academic year while they are paid fully by the Faculty. The answers to such questions can have important consequences, because Federal cost-accounting rules treat explicit commitments of effort in proposals as institutional commitments to share costs. You must report in detail on each "cost-sharing" commitment of effort, and the University must cover the associated indirect costs, leaving less overhead for the Government to reimburse.

Federal agencies now recognize that levying indirect charges on "cost-shared" faculty effort during the academic year creates a disincentive to research. Accordingly, the Office of Management and Budget recently issued a clarification, confirming that auditors will only treat effort explicitly committed in grant proposals as "cost-shared." Effort expended, but not explicitly committed in grant proposals, is not subject to certification or levies. The NSF has also directed referees and program managers not to consider voluntary commitments of effort in evaluating proposals. Under these circumstances, we must strive to avoid gratuitous commitments of effort and their costly consequences.

We and several of our sister universities are therefore suggesting that faculty members state in proposals that their universities compensate them fully for the academic year with the expectation that they will devote a substantial portion of their effort to research, but not make specific non-mandatory commitments to specific sponsored projects. In order to monitor commitments on my behalf, the Dean for Research, Professor Paul Martin will henceforth review proposals that include specific estimates of academic-year time or effort. As in the past, we shall work with you to satisfy mandatory cost-sharing conditions. On proposals that have already been submitted and awarded, you must obviously report and account for all explicitly committed effort.

Although the recent OMB clarification excludes voluntary effort from the overhead burden that cost-shared effort bears, the clarification does not eliminate mandatory cost sharing. To the relatively few federal grants in the FAS that include no summer salary and no explicit academic year commitment, the Faculty must allocate a minimal cost-sharing contribution that carries non-reimbursable indirect costs. This will be done centrally.

[Last modified: 04/16/14]

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