BIOETHICS

Letter from the Office of the Provost to all Faculty of the University of Washington

From: Office of the Provost <provost@u.washington.edu>
Date: March 16, 2007 12:42:12 AM PDT
Subject: [UW Info] Update - Faculty Effort Certification Process

This message is being sent to all Faculty with approval from the Office of the Provost.

Dear Colleagues:

I am writing to update you on the University's continued commitment to improve the Faculty Effort Certification process, the process by which faculty certify the amount of effort dedicated to sponsored research. In an effort to clarify the complex federal guidance on effort certification, the University of Washington provided extensive training to faculty receiving effort reports, departmental chairs, and administrators in the fall of 2005.

Thank you for your participation and cooperation in that training program. The Grants Information Memorandum #35 was also developed to assist in our compliance efforts. It is available at http://www.washington.edu/research/osp/gim/gim35.html. As you are aware, these efforts were initiated to support our commitment to comply with all policies, rules, and laws governing the conduct of our research.

Despite these efforts, I recognize that the effort reporting process continues to be a significant concern for many of you. In addition, faculty who are funded solely or primarily from sponsored programs have expressed particular concern about decreases in external funding and the ongoing challenge of providing sufficient institutional support for non-grant activity, such as writing grant applications. I am working with the deans and chancellors to ensure that schools, colleges, and campuses are developing policies and procedures for managing non-grant activity and working with faculty members engaged in non-grant activity to address effort reporting and funding issues.

I want to reiterate guidance provided in Grants Information Memorandum #35:

The total UW institutional base salary, including administrative and endowed supplements (ADS and ENS), must be distributed across all of a faculty member's university research, instruction, administration, service and/or clinical activities. This requirement may not be avoided by characterizing true UW activities such as proposal writing, instruction, university-related administrative duties, service or clinical activities as "unfunded" or "volunteer" activity for which no UW salary is paid.

And, from an associated "Frequently Asked Question":

To the extent such activities are de minimis in amount, meaning that in the aggregate their inclusion in or exclusion from total effort would not affect the percentages of effort allocated to sponsored research, separate tracking and funding is not required.

In addition, the University has been engaged in several efforts to continue to improve the effort reporting process for faculty, both locally and nationally:

• Nationally, the University of Washington is one of several institutionsworking together through the American Association of Universities (AAU), theCouncil on Governmental Relations (COGR), and the Association of AmericanMedical Colleges (AAMC) to improve clarity in effort reporting guidelinesand obtain flexibility. Not only have effort reporting "best practices"been developed, but a list of topics that are candidates for negotiationwith the federal government has been drafted. Although there are many stepsnecessary before the topics for discussion are finalized, some of the issuesemerging are the need for either clarification or more flexibility on:
  • Interpretations of full workload and volunteer effort
  • NSF summer salary requirements and academic year/summer effort
  • Establishing reasonable flexibility between pay and activity level
  • Reversing recent audit trends that identify proposals equaling more than 100% as an "over-commitment"
  • Providing more flexibility for effort shared between related projects
    
    
• Locally, a campus-wide team is examining options for improving theuniversity's effort reporting process. Both vendor solutions and UW builtsolutions are under consideration. In addition to the administratorsinvolved in the process improvement team, this effort has a faculty advisorycommittee to ensure a faculty voice in the process.
  
  
• An Effort Reporting Compliance Advisory Team has been developed toprovide a continued campus voice in evolving local and national effortreporting discussions. This team includes faculty, staff, andadministrators.

Thank you for your continued commitment and dedication to assuring that theUniversity is in full compliance with relevant rules and for your dedicationto the advancement of the University's research mission.

Sincerely,
Phyllis M. Wise
Provost and Vice President for Academic Affairs
If you have any questions or concerns, please contactprovost@u.washington.edu.