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Promises, Promises: How The Effort Commitments Made In Proposals May Come Back To Haunt You

2. PRACTICAL CHALLENGES IN MANAGING EFFORT COMMITMENTSProposal stageIdentifying all effort pledgesCommitments in narrative vs. cost sharing specifically identified in budget / budget justificationInstitutional policyAward stageWhat should be tracked?Effort vs. commitment vs. payroll char

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Promises, Promises: How The Effort Commitments Made In Proposals May Come Back To Haunt You

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    1. Promises, Promises: How The Effort Commitments Made In Proposals May Come Back To Haunt You Tracey Fraser, Associate Controller, California institute of Technology Jennifer Hubert, Director Huron Consulting

    2. 2 PRACTICAL CHALLENGES IN MANAGING EFFORT COMMITMENTS Proposal stage Identifying all effort pledges Commitments in narrative vs. cost sharing specifically identified in budget / budget justification Institutional policy Award stage What should be tracked? Effort vs. commitment vs. payroll charges Voluntary committed effort vs. voluntary uncommitted effort How to track and certify commitments? How sophisticated a system is required? Monitoring Addressing changes in level of commitment What needs to be reported and who should monitor? Over committing effort 100% effort Consistency in reporting: Do progress reports, effort reports and current and pending support all have to be consistent? F&A impact

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    5. 5 Effort Commitments: Importance Regulatory Requirement: NIH Grants Policy Statement update (Dec. 2003) – http://grants.nih.gov/grants/policy/nihgps_2003/index.htm Commitment overlap occurs when a person's time commitment exceeds 100 percent, whether or not salary support is requested in the application. DHHS/OIG Audit Workplans (2005-2007)– http://www.oig.hhs.gov/publications/docs/workplan/ Level of Commitment: review whether major research universities committed more than 100% of PI’s effort when applying for NIH grants

    6. 6 Effective Effort Commitment Management should do the following… Track “100% effort” for both Sponsored and Non-Sponsored Activities Charged and cost shared to sponsors Teaching, clinical, administrative, other professional activities Allow for planning of commitments in flexible time periods Effort commitments typically do not easily match certification periods Should be able to plan by specific dates (months, weeks, etc) to allow for shorter commitments (service, clinical, teaching) Identify of potential over-commitment situations Enable consistent reporting

    7. 7 Overview of a sample Effort Commitment Management process and system

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