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University of Illinois at Chicago Effort Reporting Policies

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As a recipient of sponsored funds, the University must assure Federal and other sponsors that the assignment of time and associated salary and fringe benefit costs to the projects they sponsor is reasonable in relationship to the work performed, and that commitments to sponsors have been met. The University’s effort reporting policies are the means by which this responsibility is fulfilled. Inadequate effort reporting or failure to comply with these policies and requirements can lead to financial penalties, expenditure disallowances, loss of funding, and harm to the University’s reputation.

Purpose: The purpose of this document is to provide guidance to faculty and staff on key policies governing the University of Illinois at Chicago’s effort reporting system. Effort reporting encompasses many processes, including calculating and committing effort in proposals, charging and cost sharing salary expenses for effort, and certifying effort to support commitments and salary charges.

Federal regulations provide a basic regulatory framework for effort reporting (e.g., Office of Management and Budget (OMB) 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (“Uniform Guidance”), OMB Circular A-21, and other publications such as the Department of Health and Human Services Public Health Services Grants Policy). The UIC policies build upon this regulatory framework to promote the successful management of effort, while recognizing the complexities and ambiguities of effort reporting and the challenges of federal compliance.

These policies, and the procedures, electronic forms, data and systems used in effort reporting will continue to be evaluated for opportunities to improve their effectiveness.

Campus Policies on Faculty and Faculty Administrative Appointments

Campus Policies on Calculation of Institutional Base Salary (IBS)

IBS is the annual compensation paid by the University for an employee’s appointment, and it reflects the individual’s total professional effort at the university (including research, teaching, patient care, and other activities). IBS excludes any income that an individual earns outside of their duties for the University.

OMB Uniform Guidance Section 200.430 states, “IBS is defined as the annual compensation paid by an IHE for an individual’s appointment, whether that individual’s time is spent on research, instruction, administration, or other activities.”

The IBS is used to propose and charge salary to sponsored projects, and per federal regulations, IBS must be a guaranteed amount provided to an individual for the year. That means that IBS cannot fluctuate solely based on changes in funding or activities. IBS listed in proposal budgets must be accurate and should be verified at the time of proposal submission.

Campus Policies on Effort Reporting

Effort refers to the time spent on all university activities (e.g., instruction, organized and departmental research, public service, administration, patient services, internal consulting, student services, auxiliaries and other institutional activities). It excludes external consulting, Veteran’s Administration (VA) appointments, other non-institutional professional activities (e.g.,, Stroger Hospital, Fermilab), or volunteer/unfunded activities such as community service.

Individuals are expected to devote100% of their workload to fulfilling their total professional commitment to the University, and in general, UIC considers a full workload (or 100% effort) to be no less than 40 hours and reasonably no more than 80 hours per week.

Effort reporting is the process of monitoring and validating 100% of an individual’s total professional effort. It includes the time spent working on sponsored projects in which salary is directly charged or cost shared. To receive funding, UIC must maintain an accurate system for certifying effort. The system must specifically track the percentage of effort dedicated to sponsored projects. Effort reporting serves as a way to reconcile that salaries and wages chargedor cost shared to sponsored projects are consistent with the effort committed and contributed to sponsored programs.

Campus Policies on Cost Sharing

Cost sharing is the University’s financial contribution toward a sponsored project. It includes all expenses related to grant or contract funds that are borne by the institution rather than by the sponsoring agency. If salary and fringe benefits were cost shared, it would mean that these costs would not be charged to the grant or contract, but to another source of funds and this would have to be documented for effort reporting, as required by federal regulations. This documentation is Page 8 of 10accomplished through the University’s effort reporting system. Committed cost sharing is subject to audit under federal and other sponsor regulations, and it is the responsibility of the principal investigator to manage cost-share commitments in accordance with applicable federal regulations and UIC policies.

At UIC, “cost sharing” may be referred to in many ways (e.g., matching, donated effort, in-kind contributions). No matter what the terminology, all of these commitments are subject to the following policies on cost sharing. There are three basic categories of cost sharing:

  • Mandatory Committed Cost Sharing is required by the sponsor and included in the proposal budget or budget justification. This type of cost sharing is a contractual commitment by the University to the agency. Since the University is contractually required to meet this cost-sharing commitment, it must be tracked and accounted for in the effort certification system.
  • Voluntary Committed Cost Sharing is not required by the sponsor, but is included in the proposal budget or budget justification anyway. This type of cost sharing is also a contractual commitment by the University to the agency. Since the University is contractually required to meet this cost sharing commitment, it, too, must be tracked and accounted for in the effort certification system.
  • Voluntary Uncommitted Cost Sharing is effort above and beyond what is committed to in the proposal. It is not required by the sponsor and is not included in the proposal budget or budget justification. This type of cost sharing is not in writing, and there is no contractual commitment by the University to the agency. Since there is not a contractual agreement, voluntary uncommitted cost sharing is not tracked and accounted for in the effort certification system.

Sponsors may view any suggestion of additional work on a sponsored project as a cost-share commitment, even if there is no specific amount of time, effort, or funding listed in the proposal. Therefore, including statements in a proposal such as “in addition to his committed work as the Principal Investigator, Professor Smith will also assist with …” represent a cost-share commitment, and as such must be approved at the college level, tracked at the departmental level, and accounted for in the effort reporting system.

Please note that cost sharing commitments can also be created after awards are received if an investigator’s budgeted salary is not charged to the sponsored programs. This happens most often where personnel expenses are charged to other fund sources (e.g. state or ICR funds) rather than to the grant, usually to make those grant funds available for other research-related expenses. The cost sharing created by moving personnel expenses to non-grant fund sources must be approved at the college level, tracked at the departmental level, and accounted for in the effort reporting system.

Requests for Exceptions to Policies

With the exception of the campus policies on Faculty and Faculty Administrative Appointments, requests for exceptions to any of these policies must (1) include the nature of the exception and why the exception is being requested, (2) be submitted in writing and approved by the Department Head and Dean, and (3) routed to the Office of the Executive Assistant Vice President for Business and Finance for final approval/disapproval. Individuals and departments must receive official, written notification from the Office of the Executive Assistant Vice President for Business and Finance that their request for exception to UIC policy has been approved prior to taking any actions that are not in compliance with policy.

For exceptions to the policies on Faculty and Faculty Administrative Appointments, the same information should be forwarded to the Vice Provost for Faculty Affairs for final approval/disapproval.