Policy Number: 6-5
Policy Name: Effort Certification Reporting
Date: April 30, 1984
Revisions: June 5, 1989; March 1, 1996; September 1, 2005; January 18, 2008; August 8, 2008, January 2009, July 2009; September, 2010; August 10, 2011; August 2012
To comply with the federal Office of Management and Budget (OMB) Circular A-21 requirements for effort reporting.
Certifications of Effort on sponsored awards are required for every University employee whose salary or wages are directly charged to a sponsored program account or whose salary or wages are used as cost sharing for a sponsored program. An individual must account for 100 percent of his or her activities which are part of their institutional base salary (see definition of IBS below).
Certifications must be completed in an accurate and timely manner in order to confirm that percentages of pay allocated were truly in accord with percentages of effort performed and that effort provided was at least equal to the level of effort committed (see definition of committed effort).
OMB circular A-21 requires effort certification for the following employees:
The circular outlines different reporting requirements for hourly wage earners vs. salaried employees.
(Including, but not limited to, faculty, professional & salaried staff, graduate and postdoctoral fellows, and graduate and postdoctoral researchers, and all exempt employees).
The University divides each year into three effort reporting periods. Two of these apply to all salaried staff who are required to report effort. The third reporting period applies only to faculty on academic appointments of less than 12 months. The Fall reporting period covers activities occurring during the fall semester for employees on 9, 10, or 11 month contracts, or during the six month period from September through February for all other employees. Likewise, the Spring reporting period covers activities occurring in the spring semester for 9 month employees, or during the six month period from March to August for all other employees. The third effort reporting period captures sponsored effort performed outside of a faculty member’s contract requirements. This would typically consist of sponsored research performed in the summer months of June, July or August.
Following the end of each reporting period, the Research Office will use the Effort Certification System to produce web reports for review. The reports will list effort commitments made by the individual to individual projects and will provide data to show how the individual's salary charges were allocated for the reporting period. Note that commitments and allocations are processed in different systems, and salary allocations are not directly guided by effort commitments. The actual distribution of salary payments as shown on the effort report, may or may not be appropriate for the amount of effort actually performed. If, in retrospect, the salary allocations do not represent the actual effort provided, the allocations must be adjusted in order to produce a true report. While it is expected that changes in work distribution will lead to timely redistributions of salary as a result of regular account monitoring, in the event that the reported salary allocations are not in line with the actual effort provided by the individual, a cost transfer must be processed according to the University's cost transfer policy. A journal voucher (JV) must be submitted via the Effort Reporting System to correct the allocation of salary and thereby reflect true percentages of effort.
The effort reported will always total 100 percent, even if the individual was employed for less than the six-month period, and regardless of the number of hours worked because the denominator/base is the total effort provided by the individual as a University of Delaware employee. The report must cover all effort compensated for by the University as part of the individual's institutional base salary (IBS), including sponsored research, cost share to sponsored research, departmental research, instruction, administration/university service, and public service by purpose and project codes. IBS inclusions and exclusions are listed in the definitions section below. Effort reports must not be confused with faculty workload plans, which may have guided the allocation of their salary, but might not be equivalent to their actual division of effort.
A 5 percent standard or tolerance level has been determined for evaluation of salary distribution as it relates to that which the employee certifies. It is expected that the employee will certify to within 5 percentage points of that which is allocated to the project. Example: 50% of salary allocated to a project is acceptable for an employee certifying 45% and 55% effort for that period.
HOURLY WAGE EARNERS
(Including, but not limited to, miscellaneous wage and bi-weekly employees).
Hourly wage earners who receive pay from sponsored projects must complete a time sheet recording their hours of work at least on a monthly basis. This reporting must include purpose or project codes and requires supervisory signature for approval. To monitor compliance of this requirement, the Research Office will perform semi-annual audits on a sample of charges allocated to sponsored projects.
REVISIONS OF COMPLETED EFFORT CERTIFICATIONSIn rare circumstances, a revised effort report may be created to allow an updated/revised version of an individual report which had already been certified and completed. Creation of revised reports is limited to Research Office staff, and requires a written request to the Manager of Effort Certification, including a valid justification. Reports created for approved revisions must be completed within 30 days following the date of release and may be deleted if not completed within that time frame. Revisions requested to remove unallowable charges from sponsored projects will always be approved. If a revision is needed in order to remove a salary cost over-run from a sponsored project, the charges will be required to be transferred to a non-sponsored account as cost-share.
Any statement made by an employee operating as a principal investigator or key person on a grant in reference to the time dedicated to a project or award is considered a commitment on the part of the University of Delaware to ensure this time/effort is provided to the project. This commitment may be direct charged to a grant or can be borne of university costs. Quantifiable commitments made anywhere in a grant proposal are binding upon acceptance of a resulting award, regardless of whether they are included in the budget.
Non-sponsored research effort performed by faculty as part of their appointment commitment to the department. Time spent writing grant proposals is always categorized as department research because it is not allowable to allocate that effort to a sponsored project.
An employee’s certification of his/her effort report is an affirmation that his or her percentages of effort are accurately and completely reflected. Knowingly certifying a false effort report is a violation of University policy and could potentially result in civil or criminal penalties for fraud. An effort administrator’s certification of another employee’s effort report is an affirmation that he or she believes that the salary allocations are accurately reflected on the report.
Effort Reporting System
The Effort Reporting System is an electronic web-based application, which gathers data from HR personnel data, People Soft grants data, and the University’s financial reporting system to produce and route electronic reporting forms after each reporting period, or as needed.
Institutional Base Salary
The University of Delaware has defined the IBS as an individual’s total contractual compensation from the university as is defined in a standard offer letter. Payments for work outside of the duties for which one was hired, are not part of the IBS. The following table illustrates types of faculty activities which are or are not included in the IBS.
|Activities included in the IBS||Activities outside of the IBS|
Note that many activities included in the IBS may not be charged to sponsored awards. Non-sponsored funding must be used to support the following effort unless the award documentation clearly allows them: instruction, course development, and advisement of students if not for a specific research award, administrative assignments such as department chair or dean, writing of grant proposals unless for a non-competitive renewal, service on committees or review boards or as a primary journal editor, review of peer manuscripts, fundraising, and lobbying. Since most faculty members participate in activities such as these, it should be extremely rare for any faculty member to be 100% grant-funded.
Suitable Means Of Verification
An employee evaluating effort on behalf of a terminated or otherwise incapable employee must be able to represent a reasonable relationship to that employee’s work such that validation of time spent on reported projects is achievable. A faculty advisor, supervisor, or project PI on that project is such an example. Documentation of verification must be retained in the department as backup to support the certification by anyone other than the employees themselves.
The Research Office
The Manager of Effort Certification is responsible for ensuring that the University’s effort reporting system meets the requirements of the federal government and adheres to University policies. The Research Office will have ten days following the posting of an reporting period’s ending salary transactions to produce and release the reports to the Effort Administrators. Electronic copies are retained in the Research Office for the retention period required by the sponsored agreement, usually three years after the closeout or final payment of the project.
Departmental Effort Administrator
Each academic department or unit which has employees paid from sponsored funding sources must have one staff member assigned as the Effort Administrator. The Effort Administrator’s role is to facilitate the timely and accurate completion of their department’s effort reports. They are responsible for reviewing reports for errors in funding amounts and sources, distributing the reports to each individual for certification, making any necessary adjustments to salary allocations, and completing the reporting process prior to the deadline which is 90 days following the end of the reporting period. They are also responsible for requesting omitted reports when needed so that required reporting is accomplished for all employees.
All faculty who are involved in allocation of salaries and wages to sponsored projects are responsible for understanding the importance of effort reporting compliance as it relates to proper grant management. Faculty members must be aware of their own levels of effort committed to sponsored projects and ensure that they have the ability to meet those commitments while simultaneously meeting their obligations to the University without over-committing themselves. They must also communicate any substantial changes in effort to their department or college administrators in a timely manner. This includes effort changes for themselves as well as any other employees working on their sponsored research projects.
Internal AuditThe Internal Audit Department will conduct independent evaluations of the Effort Reporting System required by OMB circular A-21 every three years.
BackgroundPolicies and Practices: Compensation, Effort Commitments, and Certification. An invaluable source of information about federal requirements and how to interpret them, issued in March 2007 by the Council On Governmental Relations (COGR, of which UD is a member).
ProceduresUniversity of Delaware Effort Certification procedures are available to guide the effort administrator through the process.
Submitted by: Research Office