Guidance and FAQS regarding the SOM Policy on Protected Time for Non-Sponsored Activities

This applies to Faculty/PIs with any sponsored research, not just federally funded research

NIH and the Department of HHS expect an accurate reflection of time spent specifically related to the funded project when charging Federal awards and certifying effort (2 CFR §200). There have been recent audits findings related to inappropriately charging time spent on non-sponsored activities to federal awards. For example, in 2020 The Scripps Research Institute agreed to pay the U.S. $10 million to settle claims that it improperly charged NIH-funded research grants for time spent by researchers on non-grant related activities such as developing, preparing, and writing new grant applications, teaching, and engaging in other administrative activities. See press release here.

Yes. 0.6 PM of protected time is needed to complete all other responsibilities that individuals may have that are unrelated to sponsored research, career development activities, or specific other committed cost centers. K-Awardees may hold other formal roles that would require additional protected time

A formal role is a named academic administrative role that has some defined responsibility/effort associated with it, whether paid or not paid. Some of these 'formal' roles may require more day-to-day effort/responsibilities that others (for example a Division Chief or Chair). Therefore, we must rely on the Department to make a reasonable determination for what effort is required for role, and if it can be fulfilled within the 0.6 or 1.2 PM protected time. See Q11 for further details around formal leadership roles

• Example:
  • Faculty Member A has a formal, unpaid role as an IRB/IACUC reviewer. The department would normally consider this effort as part of the occasional academic activities covered in the “5% of Duke Appointment” effort previously. Under the Appointment Model, will this still fall within the 0.6 PM of protected time, or is the full 1.2 PM needed because it is a “named” role? The role only requires about ½ a day of work per month
  • As noted, protected time must be commensurate with the level of effort required to fulfill professional responsibilities. For this specific example, it appears that the 0.6 PM of protected time would be appropriate, based on the details provided, and assuming the 0.6 is adequate to complete all other responsibilities that this individual may have that are unrelated to sponsored research or specific other cost centers that he or she is on

​​​​​​Yes, any formal academic administrative role requires the appropriate time be protected (1.2 PM in this example), regardless of the compensation associated.

“Academic Administrative Leadership” role examples are: Residency Program Director, Assoc Residency Program Director, Fellowship Program Director, Vice Chair for Research, Division Chief, Center (small “c” or large “c”) Director, IRB Chair, Chief, Chair, Advisory Dean, Course Director, etc.

​​​​​No, the 1.2 PM encompasses all protected time needed for that individual

No, this is not currently part of their Duke University Appointment and does not affect the required 0.6 PM Protected Time for non-sponsored activities

If protected time is appropriate to be implemented moving forward (i.e. the faculty member will be protected 0.6 PM for non-sponsored activities starting today), the changes can be made from a current date. However, all changes must be in effect no later than November 1, 2022 (thus entered in iForms by the November payroll deadline). The change can be retroactive to July 1 if it is truly reflective of how the faculty member was spending their time. No changes should be made retroactive prior to July 1, 2022 (point of transition to Appt Model). Please reach out to ORA for specific questions/scenarios

Submit a Redcap Survey Form for the effort shift to capture the 0.6 or 1.2 PMs. Departments will have to show/explain a clinical work reduction within the form

Yes, “protected time for non-sponsored activities” must be charged to a non-sponsored, internal fund code (for example, 1XX, 2XX, and 4XX, excluding codes that end in “3”). Please see Duke’s Accounting Codes Overview for further explanation on fund codes

Note that, per the policy, “Protected Time for Non-Sponsored Activities” is for all non-sponsored activities, not just administrative activities. Non-sponsored activities that may be performed within this Protected Time include but are not limited to: Teaching, Proposal Writing, Academic Leadership Roles, Service on University Committees, Mentoring, Writing Publications, Department/Division Meetings, Departmental Research, Required Trainings, Interview Participation (ex: interviewing candidates for faculty, students, residents, postdocs and fellowship programs), Other Administrative Duties. Therefore, “protected time” may be charged to any or multiple of these internal codes. The 602300 and 603000 are appropriate codes for recording protected effort, though are not the only codes. See Duke’s Payroll Costs > Definition of GL Accounts for further explanation of GL codes

• Note: This is in alignment with Duke’s previous policies around “5%” or “10%” protected time​​​​​​​

The spirit of “protected time” is to ensure that faculty members are not charging 100% of their available Duke time to sponsored projects. Therefore, it may be helpful to think about the policy not as “protect 0.6 PM for non-sponsored activities”, but “do not charge all available PM to sponsored projects.” For example, if someone has a 75% Duke Appointment, and 9 PM available for Duke activities, they cannot charge more than 8.4 PM to sponsored projects

A charge to a “Sponsored Fund” is drawing from a reportable WBSE in the following series: AXX, 2XX and 3XX except for 391, and including funds that end in “3”.  This can be found by running the "Cost Distribution by Employee Org Unit" report in the Grants Management Tab in Duke@Work

Example: If a 12-month faculty member has a 75% Duke Appointment, then they have 9 PM available for Duke activities (75% of their total 12 possible PMs). Their protected time is 0.6 PM of this 9 PM available; thus, the internal allocation of this protected time would be (0.6/9) = 6.67% of their total Duke allocation