Research and Sponsored Programs

Office of the Vice Chancellor for Research and Graduate Education

Effort Frequently Asked Questions

Page Updated: Tuesday, June 13, 2023 9:21:44 AM CDT

Question 1: What is Institutional Base Salary (IBS)?

Institutional base salary (IBS) is the annual compensation paid by the University of Wisconsin-Madison for an employee's appointment, whether that individual's time is spent on research, instruction, administration, or service. Institutional base salary excludes any income that an individual is permitted to earn outside of duties for UW-Madison. It also excludes any compensation paid by the UW Medical Foundation. It may include salary paid from State funds, grants or contracts, gifts and endowments, and/or other UW funds.

Question 2: What types of activities can I charge to my sponsored project?

• Directing or participating in any aspect of the research related to the specific project
• Providing research patient care
• Writing a progress report for the project, sometimes called a continuation proposal
• Holding a meeting with lab staff to discuss the specific research project
• Activities contributing and intimately related to work under the agreement, including:
• Participating in appropriate seminars
• Consulting with colleagues about specific aspects of the project
• Delivering special lectures about specific aspects of the ongoing activity
• Attending a scientific conference held by an outside professional society to present research results
• Reading scientific journals to keep up to date with the latest developments in one's field
• Mentoring graduate students on the specific research project
• Making an invention disclosure, and some other activities related to pursuing intellectual property

Question 3: A PI in my department wants to change time spent writing a new proposal to one of their grants. Is that ok?

No. The following cannot be charged to a sponsored project. Instead, these activities should be charged to non-sponsored funding.

• Proposal writing, except for non-competing continuations (progress reports); this includes:
• Developing necessary data to support the proposal
• Writing, editing, and submitting the proposal
• Administration, including service as a department chair or dean
• Instruction, office hours, counseling for students, and mentoring graduate students on something other than a specific research project
• Clinical activity, except patient care for an IRB-approved sponsored research activity
• Service on an IRB, IACUC, selection committee, or other similar group
• Course or curriculum development not specific to the faculty member's research project
• Writing textbook chapters
• Fundraising
• Lobbying
• Work that falls outside of the definition of Total UW Effort (see the complete definition in the Effort Glossary), such as:
• Service as the primary editor of a journal
• Peer review of manuscripts, regardless of whether compensation is received
• Advisory activities for sponsors, including service on an NIH study section or NSF review panel, regardless of whether compensation is received

Question 4: What provision is made to provide money for grant application preparation for research faculty paid 100% on federal grants? What is the source of the funds and who is responsible for providing those funds for grant application preparation?

Faculty should consult with their department administrator and chair to determine the source of funding for non-grant activities. While not all nonfederal grants and contracts are subject to the same rules as federal grants and contracts, it would be very unusual for any sponsored funding source to allow funds to support a new grant proposal. Generally, any departmental/school sources, including but not limited to 101 (GPR) funds, gifts, endowments, etc., should be used to fund these activities. Departments and colleges are responsible for assuring that provisions for funding are in place.

Question 5: Can proposal writing be considered "de minimis"?

No. Only Infrequent, irregular activity that would normally be considered "so small" that it is not statistically significant can be categorized as de minimis effort. Activities can be considered de minimis in amount when, in the aggregate, they represent less than one percent of the individual's Total UW Effort. Grant proposal writing is a well-defined, regular administrative activity. Therefore, it cannot be treated as de minimis activity.

Question 6: What is the minimum amount of time a faculty member needs to have available for administrative activities like proposal writing?

There is no guideline or directive from the UW (or the federal government) regarding a minimum. Each individual's portfolio of activities should be reviewed to determine the appropriate mix of grant and non-grant funding for the individual.

Faculty members, because of the scope of their activities associated with university effort, generally may not be 100% research. Academic staff may in some cases have their salary charged 100% to sponsored projects. However, charges to sponsored agreements may only include reasonable amounts for activities contributing to and directly related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. If the teaching and other activities are NOT contributing to and directly related to the work under the agreements that are paying the salary, then a portion of the individual's salary proportionate to the non-grant activities must be paid from other sources.

Question 7: Can effort related to pursuing intellectual property (e.g., making an invention disclosure, meeting with WARF to discuss an invention disclosure, reviewing internal action on a patent application and/or reviewing a draft patent application) be directly charged to grants?

Yes. Consistent with the spirit of Bayh-Dole, reasonable levels of activity related to pursuing intellectual property can be charged directly to the appropriate grant. As with any effort charged to sponsored agreements, effort associated with the pursuit of intellectual property must be directly related to the sponsored project that is being charged. Where more than one award or activity contributed to the development of the intellectual property, the effort distribution should be based on proportionate support provided under the awards or other equitable relationship. The effort must also occur within the award period.

Question 8: An Emeritus faculty member has been hired back at a 40% appointment to teach. Can this individual "volunteer" time on a sponsored research project?

No. The effort devoted to the sponsored project must be considered part of the individual's Total UW Effort. Activities that are closely associated with your UW-Madison professional duties must be reported as UW effort/compensation.

Some of those activities are: proposal writing, instruction, University-related administrative duties and service on committees. You cannot characterize them as "unfunded" or "volunteer" activities or "weekend work," for which no UW-Madison salary is paid, because federal regulations prohibit this.

Question 9: Is there a minimum level of effort required for PIs on sponsored projects?

Yes, but only on federal projects. The principal investigator's minimum required effort commitment to federal and federal flow-through projects is 1% of their effort. This minimum requirement does not apply to nonfederal sponsored projects or federal equipment, doctoral dissertation, and student augmentation grants. Certain nonfederal sponsors, however, may have specific minimum requirements. While the 1% is not required by UW-Madison policy for nonfederal awards, it is recommended that PIs propose and devote a minimum of 1% effort to all sponsored projects to carry out the essential scientific, administrative and fiscal responsibilities needed for the research.

Question 10: Can a faculty member be noted as contributing to a grant without committing effort?

Yes. The “Other Significant Contributors” filed on NIH proposals allows the PI to identify individuals who have committed to contribute to the scientific development or execution of the project but are not committing any specified measurable effort.

The following is a quote from the NIH 424 (R&R) instructions: "OSCs are individuals who have committed to contribute to the scientific development or execution of the project but are not committing any specified measurable effort (in person months) to the project. These individuals are typically presented at effort of zero person months or as needed (individuals with measurable effort cannot be listed as Other Significant Contributors). Consultants should be included if they meet this definition. This would also be an appropriate designation for mentors on Career awards."

Question 11: What about vacation time when there are multiple grants? How does one ensure that each grant pays their fair share of vacation time?

The university applies a consistent practice of paying vacation and other accrued leave from the funding in place at the time the leave is taken. If grant funds are not being used to support the individual at the time leave is taken, the department will cover the leave costs. This is a fairly common practice at institutions and is viewed as acceptable because we are consistent in the application and do not discriminate between funding sources.

Question 12: I want to reduce my effort on a NIH project by half. Do I need to do anything special aside from letting my Program Officer know?

Yes. While it is important that the researcher maintains a good relationship with the Program Officer, this is not sufficient. Decreases in effort of 25% or more by key personnel (as listed in the Notice of Grant Award) must be approved prior to the change and in writing by the sponsor's Grants Officer. The request must be processed through RSP in advance of the change. The exception is for NIH awards - if the reduction in level of effort is addressed in the RPPR, and the next year’s funding is received, the reduction is deemed approved. A separate prior approval letter does not need to be sent to NIH.

An increase in effort greater than 25% for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored agreements. If there is a change in the scope of work, it must be approved prior to the change and in writing by the sponsor's Grants Officer. The request must be processed through the UW Office of Research and Sponsored Programs in advance of the change.

Question 13: I just received a 12-month no-cost extension. Does my original commitment extend into that period?

Except for grant programs that have a specific minimum effort requirement, effort commitments are not required to be updated when requesting or receiving a no-cost extension (NCE). A thorough analysis of sponsor polices and federal regulations have concluded that a NCE simply provides additional time in which the originally proposed effort may take place.

Rarely, there might be instances when a commitment is necessary during the NCE period. Specific grant programs may require a specific minimum effort requirement, which continues into the NCE period (i.e., NIH award types: K, R35, DP1). Therefore, before preparing the NCE request, review the terms and conditions of your award to determine if a specific commitment must continue.

Question 14: What risk areas should we focus on as a school, college, or department?

• 100% research faculty - are they involved in activities that should be funded by sources other than their grants?
• Faculty with 5 or more federal awards - are they overcommitted? Are the percentages of salary distributed to each of their projects reasonable?
• Change in Level of Effort - are faculty seeking permission to change the level of effort proposed in their grant when required (typically when the change is 25% or more)?
• Faculty with 1 or 2% of their effort on many awards - are they contributing the effort promised?
• Faculty Payroll Certification - is it timely?
• Retroactive Salary Cost Transfers - are they infrequent, but timely when necessary? Of particular concern are those affecting time periods for which faculty have already certified.
• Total effort commitments (paid and cost shared) to the sponsor - are they met?

Question 15: Where can I go if I have more questions?

For questions regarding effort, contact effort@rsp.wisc.edu.