Punching the Research Effort Clock

As observed today in Nature (& blogged here earlier in the year), the NSF is doing a very precise time audit of funded researchers to ensure they actually spend as much time as they are paid for on specific projects. So far, UPenn and Caltech have been scrutinized and found wanting (Caltech took a hit to their indirect cost rate). The next batch of reports will cover UC San Diego, UC Berkeley, U Utah, U Ill Urb-Cham, and Vanderbilt. Not surprisingly, everyone is being tight-lipped about the entire process. So much for NSF’s concern about administrative burden.

Update: Speak of the devil. The US DHHS Office of the Inspector General has released its FY08 Work Plan. Among the fun doings to anticipate, “We will review administrative and clerical salaries charged to federally sponsored grants and cooperative agreements by colleges and universities…. We will review colleges’ and universities’ compliance with selected aspects of OMB Circular A-21. … We will review NIH’s monitoring of extramural grantees for potential conflicts of interest. We will focus on financial conflicts of interest that grantee institutions report to NIH, as well as the extent to which NIH oversees grantees’ monitoring and management of potential financial conflicts of interest.” And somehow this slipped past those crack federal editors: “We will review the extent to which Data and Safety Monitoring Boards (DSMB) in clinical trials.” Hmmm.

Our friend Brian Martinson and his group in Minnesota note that misreporting is the norm: 70% of mid-career scientists winning their first R01 use at least some of the funds for other projects. Of course, this is getting harder to do now when the NIH lops 20% off your approved budget just for starters.

All I can say is wait until the CTSAers have to start logging in NUMBERS OF HOURS PER PERSON OR PROJECT (fractions of hours even!) in a central database. I am so far behind logging in my own effort it isn’t funny … and it really puts a damper on wanting to help people because, damn, then I have to log the hours and probably create a new account describing the person & their research & exactly what CTSA services they received. Criminey. Nothing like making the support of innovative translational research such a joy.

10 Comments »

  1. drugmonkey said

    this is so bloody STUPID! the Nature thing is all about documenting time spent- it can’t be done. How do they account for the times you wake up in the middle of the night thinking through your latest research problem? Time in the shower rehearsing the edits you are going to make to the paper?

    obviously since we’re talking about documentation this is about institutions screwing up the percentatge efforts they assign on an ongoing basis. And even this is stupid. Say I have three grants. I assign 33%, 33% and 34% effort. Does my real effort match this across the month or year? Likely not. How do I know which paper is going to suck up more than expected time? Which research prep is going to go south and which is going to be unexpectedly smooth?

    And there’s overlap. If you go to a conference on Grant #1s dime do you really not talk about the science on Grants #2 and #3? Sure you do.

    Perhaps the real solution here is to match the paperwork to the practices of the industry instead of trying to fit some irrelevant company derived scheme onto our rather unique business.

    Preachin’ to the choir, DM. I think all they want is numbers on all the paperwork to match up a la Brazil. But now you’ve reminded me that I probably do need to log my 1 am musings in the CTSA database. – writedit

  2. drugmonkey said

    Couple more thoughts:

    -I can’t believe you didn’t notice the comment in the Nature piece about the investigator under investigation for research misconduct. kinda willing to believe that a guilty scientific frauder would also play some games with the effort. but this might be the “piling on” approach. which is that if they can’t fully nail someone for the research fraud it might be easy to get them on a “tax fraud” technicality a la capone. be interesting to know some more detail on that one…

    I did notice, but I wouldn’t call this piling on … just a serendipitous (& probably not unexpected) finding. I wouldn’t interpret this as meaning hypervigilant RIOs will start nailing investigators for “fraud” based on poor effort reporting. – writedit

    -the Johns Hopkins reference. One thing that came out of the Hopkins audit was the nice little problem of who is paying PIs to write grants. Oh yes my friends, it is technically a no-no to use NIH funded grant time to write grant applications! You were aware of that right? As far as I can tell, the upshot was that Hopkins had to find some way to keep a small fraction of effort off the grant accounts as if the local institution was paying for the grant preparation. no doubt they found some neat accounting tricks or at worst took it out of the indirects, $$ is fungible after all.

    the fascinating thing is that this decision did not appear to be promulgated. I’ve heard of another institution or two going down this road but it seems to be a local fear issue if the dean heard about the Hopkins “problem”. What I did not see was a global pronouncement from the NIH saying “hey, we know you local institutions are doing this, you have to knock it off and come up with a way to pay all your grant writers some fraction of effort from institutional sources”.

  3. PhysioProf said

    Based on my reading of those Nature articles, my reading of the outcome of an audit performed a few years ago at my institution, and my reading of Circular A-21 regarding allowability of costs charged to Federal grant awards, I have come to the following conclusion:

    I believe that there is no chance that government auditors will ever start looking through lab notebooks, computer logs, etc. to try to determine the actual scientific content of what personnel paid by awards are doing in the lab. The issue is that there needs to be some paperwork in which the actual expended effort of personnel is documented. Circular A-21 makes it clear that for academic personnel, research, teaching, and administrative activities can be inextricably intertwined, and that all that is required is a reasonable best estimate as to the percent effort devoted to a particular award.

    In order to satisfy this requirement, and keep the auditors off your back, all you need to do is explicitly certify your percent effort on your various awards on a regular basis. And the certification needs to be prima facie reasonable: including all of the investigators activities not related to funded awards it must add up to 100%, and it must contain a reasonable percentage not devoted to funded research activities that encompasses the likely teaching/administrative burden on the person (including the preparation of new and competitive renewal grant proposals). For example, the Provost of a university who is asserting that 80% of their effort is devoted to funded research activities is going to draw some attention.

  4. drugmonkey said

    “and it must contain a reasonable percentage not devoted to funded research activities that encompasses the likely teaching/administrative burden on the person (including the preparation of new and competitive renewal grant proposals).”

    and who pays for that in a soft money institution or subdivision of a uni or job category? therein lies the rub.

  5. PhysioProf said

    My understanding of what is going on at my institution is that the highest levels have already decided that even “soft money” research positions will not be permitted to charge 100% effort to federally sponsored programs, and some % of their effort will be attributed to administrative tasks, including the preparation of competing grant applications.

    Now, of course, they need to decide who will pick up the slack. Since at my institution it is individual departments that are ultimately responsible for the salaries of all personnel, my guess is that each department will pick up some percent of their salary, and then the chairs will seek to recover those costs in their general budget allocation from the institution.

    One interesting question that arises out of this discussion is the status of grad students and post-doctoral associates who are paid by sponsored research grants. It is universal that these people are 100% supported by sponsored programs. While I believe that a good argument could be made that it is an appropriate practice under Circular A-21, the opposite argument could probably also be made.

    PhysioProf, it’s not universal that all postdocs are supported by sponsored programs. My prior institution has a category of “affiliated” postdocs, meaning they are paid by industry (eg, Philip Morris) but are trained in University facilities by University faculty. More broadly, though, the National Postdoc Assoc recently sought & received clarification from the NIH that Circular A-21 covers mentoring activities as part of reported effort on NIH grants. writedit

  6. PhysioProf said

    “PhysioProf, it’s not universal that all postdocs are supported by sponsored programs.”

    I know that, and it’s not what I meant. I could have phrased it more clearly, but what I asserted was that those postdocs and grad students that *are* supported by sponsored research grants are almost always supported 100%.

    “More broadly, though, the National Postdoc Assoc recently sought & received clarification from the NIH that Circular A-21 covers mentoring activities as part of reported effort on NIH grants.”

    Yeah, I know this. What about post-docs or grad students writing NRSA or other fellowship applications while supported 100% on a sponsored program?

    Usually training in grant-writing skills is written into the career development/training program for postdoctoral scholars (those on T32, T34, etc.), so they should be covered as writing their applications as part of their training regimen. For the postdoctoral associates hired 100% to work on a specific project, probably not (at least not on the NIH’s nickel). BTW, I thought your first comment quite a nice summary of the reporting issues. Not that I expected a quick note about bureaucratic auditing to generate so much commentary. – writedit

  7. bikemonkey said

    Aha! An easy out. For R21s an extremely common thing is for the applicant to describe how the Exploratory or Developmental work will lead to additional “full scale” research proposals (read, “R01”). Increasingly, I see R01s come along with “Future Directions” type sections which also happen to mention that the work would have a followup at a later date.

    So grantwriting is an explicit part of the research proposal and therefore covered, right?

  8. PhysioProf said

    “So grantwriting is an explicit part of the research proposal and therefore covered, right?”

    Nopw. I can’t find it right now, but there is an explicit statement somehwere on the NIH Web site that preparation of competing proposals–new or renewals–are not allowable costs on an NIH sponsored award.

    Not that a measly NIH policy would deter bikemonkey … – writedit

  9. […] US DHHS Office of Inspector General is very interested in effort reporting, so it could be they will offer indirect help to the NIH’s movement toward limiting awards […]

  10. […] And lest any institutions think the NSF is unlikely to ever verify their verification of satisfactory completion of RCR training, I have two words for you: effort reporting. […]

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