Policy Number: 318Responsible Office: Grants and Sponsored ResearchRevised: 7/21/16
To comply with the federal Office of Management and Budget, The Uniform Guidance 2 CFR 200 (Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards for Educational Institutions), which supercedes the previous requirements in OMB circular A-21, the University maintains and updates its comprehensive Time and Effort reporting process as specified in 2CFR 200.430
In order to certify that effort expended on a project is at least commensurate with the salary charged against the sponsored program, the University employs an after-the-fact effort reporting system for faculty, administrators, and staff who have a portion of their salary or time charged to a sponsored program. Individual effort reports are required for each cycle, as defined below, for all employees who have a portion of their salary or time charged to a sponsored program. The Office of Grants and Sponsored Research (OGSR) shall ensure full compliance with the University’s time and effort reporting requirements and along with Business Affairs, maintain full documentation, which will be available for inspection by the University’s auditors.
Faculty members’ effort commitments to sponsored projects must not exceed 95% in any effort cycle. Additionally, 100% annual or summer salary effort must never be committed to sponsored projects by any individuals who have other teaching, proposal writing, mentoring or advising students, clinical activity or other non-grant administrative duties. Departmental chairs, departmental assistant-chairs, core directors, assistant and associate deans must not exceed effort commitments to sponsored projects above 95% in any effort period. Rare exceptions may be granted in unique situations where the funding agency expressly approves of 100% effort, such as on career awards.
For purposes of meeting the standards in 2 CFR 200 and other federal requirements, the University defines three cycles of reporting:
Spring – defined as January 1 through May 31 (Unless summer pre-session applies; see below for further guidance on summer cycle).
Summer – defined as the immediate start of pre-session summer course offerings (on or about mid-May) and though August 31 of that year. (For further guidance on summer cycle, please see below).
Fall – defined as September 1 through December 31.
Further Guidance on Summer Cycle:
Supplemental/Summer Salary - Faculty compensated for 9‐month academic appointments are permitted to earn up to an additional three months of supplemental/summer paid compensation on one or more sponsored and/or non-sponsored activities. Individuals can earn up to the equivalent of three months of additional salary for that effort, subject to University and sponsor policies (e.g., Uniform Guidance 2 CFR 200) and the appropriate school level approval.
If a faculty member has administrative or other non‐sponsor related responsibilities (including vacations) during the period for which he/she is requesting supplemental salary, the faculty member is precluded from devoting the maximum allowable 95% effort to sponsored projects and cannot request the full 95% of 3 months of salary.
The University defines the maximum (100% effort) summer course load as follows:
Principal Investigator (PI)
Office of Grants and Sponsored Research (OGSR) and Business Affairs
St. John's University, New York
Human Resources Policy Manual