Section: Research
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
PURPOSE
To comply with the federal Office of Management and Budget (OMB) Circular A-21 requirements for effort reporting.
POLICY
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).
EFFORT CERTIFICATION
OMB circular A-21 outlines different reporting requirements for hourly wage earners vs. salaried employees.
SALARIED STAFFReports are required twice a year, for the six-month periods of September 1 through February 28 (or 29) and March 1 through August 31, from the following employees:
Every employee whose salary or wages are directly charged to a sponsored program account.
Every employee whose salary or wages are used as match/cost sharing for a sponsored program account.
Following each six-month reporting period, the Research Office will use the Effort Certification Systems 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 was allocated for the reporting period. The totals provided reflect the actual distribution of salary payments, which may or may not be appropriate for the amount of effort actually performed. While it is expected that changes in effort will lead to timely redistributions of salary as a a result of regular account monitoring, in the event that the reported salary allocations are not in line with the actual effort provided byt 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.
Activity reported must be 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 of the percentages is the total of all University effort. 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. 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 CERTIFICATIONS
In 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.
Committed effort
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.
Departmental Research
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.
Effort Certification
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 |
|
|
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 60 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.
Principal Investigators
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.
Background
Policies 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).Procedures
University of Delaware Effort Certification procedures are available to guide the effort adminstrator through the process.Submitted by: Research Office
