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Policy Contact: Grants and Contracts Administration

1. Purpose

   This policy and its procedures are intended to ensure compliance with federal regulations— including those found in the Uniform Guidance (2 CFR Part 200), OMB Memoranda 01-06, and in National Institutes of Health (NIH) guidance—regarding the minimum effort of key personnel on sponsored projects.

2. Definitions
    
   1. Sponsored Project: an activity funded by a non-University entity requiring the University, by written agreement, to conduct certain work under a set plan, a set schedule, and a set budget, typically for the purpose of supporting research, instruction or public service through tangible or intangible deliverables that are the ultimate result of the Project.
       
   2. University Effort: all responsibilities expected of an individual’s appointment, i.e. the time spent on any activity by an individual expressed as a percentage of their compensation without reference to any set number of hours per week. Activities include research, instruction, public service/other sponsored programs, and administration.
       
   3. Committed Effort: any portion of University Effort that is quantified and included in a program proposal and the subsequent award.
       
   4. Key Personnel: individuals who are critical leaders or contribute extensive expertise to the scope of the project. Replacement of any key personnel typically requires sponsor approval.
       
   5. Location Code: a code that is usually the same as the grant fund number and is used to track cost share salary and expenses that have been paid for by the University.
       
   6. Principal Investigator/Project Director: (“PI”/“PD”) the primary individual who is responsible and accountable for activities on a Sponsored Project.
       
3. Policy
    
   1. The University requires a minimum of one percent (1%) of each Key Personnel’s University Effort on most federal research grants, on an ongoing basis over the period of performance of the grant. In the event salary is not allowed on a grant, minimum effort will automatically be pre-approved as cost share.
       

   2. The following grants are typically excluded from the requirements of this policy:

      1. Equipment and instrumentation;
      2. Doctoral dissertations, including fellowship/scholarship awards;
      3. Training grants and mentor effort;
      4. Specific purpose grants such as travel grants, workshops, and conference support grants;
      5. National Science Foundation (NSF) Research Experiences for Undergraduates (REU) (committed effort must be present on the research grant supporting the REU);
      6. National Institutes of Health (NIH) supplements (committed effort must be present on the parent grant supporting the supplement);
      7. NIH Other Significant Contributors as cited in the NIH SF 424 Application Guide; and
      8. Non-Federal grants, unless mandated by the sponsor.

      The above is not an exhaustive list of grants, and any questions regarding a specific activity or program should be directed toward the Office of Research Assurance and Sponsored Programs (ORASP) or Grants and Contracts Administration (GCA).

   3. Minimum effort is required to be tracked and certified for a Principal Investigator/Project Director (PI/PD) and/or other Key Personnel.
       
4. Procedures
    
   1. Minimum effort is recorded by either being charged directly to the grant or provided as pre-approved cost share.
      1. Direct charge to the grant - a personnel activity report must be completed to charge at least 1% directly to the grant.
      2. Pre-approved cost share – a personnel activity report must be completed, including a line that identifies the minimum effort of at least 1% using the location code provided by GCA to record minimum effort.
          
   2. Minimum effort must be recorded annually based on the grant year.

5. Responsible Administrator

   The Director of Grants and Contracts Administration, successor, or designee is responsible for annual and ad hoc review of this policy and its procedures. The University President is responsible for approval of this policy.

Approved by President on 11/16/2018. Revised 01/30/2024 (clerical). Revised 08/05/2024 (clerical).

Sources: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; ; ;