I. SCOPE
This policy applies to all faculty who are funded via NIH Career Development Awards (K-Awards).
NIH K-Awards are an important component of Duke University’s sponsored portfolio. More importantly, they are critical to individual investigators’ professional development. In order to meet NIH’s guidelines related to effort commitments, Duke University has developed internal guidance related to K-Award management at the time of proposal and throughout the life of the award.
II. POLICY
Many K-Awards require a higher level of effort commitment than other types of awards. For K-Award eligibility and throughout the life of the award, the following minimum standard applies:
- The committed effort must be at least 75% (or the specific commitment level per the award document) of Duke University effort.
Concurrent effort may be permissible with approval from the applicable program officer and with coordination through the Office of Research Administration/Support.
III. GUIDELINE
In 2004, the NIH clarified its policy concerning effort reporting and NIH Career Development (K) Awards (NOT-OD-04-056). Because of the complexity of the University, PDC, and VA relationship, Duke University is further refining its interpretation and application of internal practices related to K-Awards. The objective in developing this guidance is to manage compliance with applicable regulations and ensure the investigator has adequate protected time to complete the award objectives.
K-Awards are designed primarily as support for new investigators, though some are designed for more senior faculty. K-Awards typically have established minimum effort requirements, most often 75%. Salary recovery is often limited to a specified amount per year, requiring the institution to cost share the difference if the faculty member’s salary is higher. A K-Award recipient’s remaining effort may be devoted to other institutional activities as long as those activities are consistent with the objectives of the K-Award. For mentored K-Awards, salary supplementation may not be from Federal funds unless specifically authorized by the Federal program. Institutional supplementation of salary must not require extra duties or responsibilities that would interfere with the purpose of the K award. Funds may be rebudgeted between categories consistent with the institution’s salary scale.
Effort commitments will be periodically monitored throughout the life of the award by the Office of Research Costing Compliance. Additionally, the School of Medicine Compliance Office will sample and audit the School of Medicine effort commitments during their department evaluations. Other areas of effort commitment will be evaluated in conjunction with the K-Award analysis including Veteran’s Administration (VA) effort.
IV. EXCEPTIONS
Exceptions must be documented and requested through the applicable Management Center Finance Office and approved by the Vice Dean/Provost for Research, with appropriate authorization from federal program officials.
This policy is an administrative policy, not a cost reimbursement policy. Failure to comply with this policy in connection with a particular K-Award may or may not result in adjustments of charges to the award. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from a K-Award for any reason, whether or not related to this policy, the cost will generally be charged to departmental funds.
V. ADDITIONAL RESOURCES
NIH’s K Kiosk Webpage
GAP 200.170, Effort Reporting
Office of Post-Award Administration
Office of Research Administration: (919) 684-5175
Office of Research Support: (919) 684-3030