Effort Certification Reporting
|Section:||Research, Sponsored Program, Technology Transfer & Intellectual Property Policies|
|Policy Name:||Effort Certification Reporting|
|Policy Owner:||Vice President for Research, Scholarship & Innovation|
|Responsible University Office:||Research Office|
|Origination 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; July 21, 2015; March 2016; May 2016; April 2019; October 2019|
|Legacy Policy Number:||6-05|
- SCOPE OF POLICY
This policy addresses the University of Delaware (“UD” or “University”) obligation to ensure compliance with the applicable federal regulations, Office of Management and Budget (OMB) Circular A-21 requirements or Uniform Guidance 2 CFR 200, for effort reporting and applies to all University departments, units, faculty, staff and students.
- “Committed Effort” is the amount or percentage of time a University employee has agreed to work on a specific Sponsored Project. It is not necessarily the actual effort expended each month, but a projected amount to be achieved over a period of time (for example, a semester or a year). This commitment is set at the time of the award.
- “Departmental Research” is non-sponsored research performed by researchers as part of their appointment commitments to their academic department at UD.
- “Effort Certification” is an employee’s documentation of his/her effort report and is an affirmation that his/her reporting of effort is accurate and complete.
- The “Effort Reporting System” is an electronic web-based application, which gathers data from Human Resources 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.
- The Institutional Base Salary (“IBS”) is 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 University employee activities which are or are not included in the IBS.
Activities included in the IBS Activities outside of the IBS
* Instruction/University supported academic effort – including student training and advisement
* Externally sponsored research – including reporting, participating in related seminars, meetings and conferences, and consultations with colleagues, graduate students or other staff supporting the research
* Departmental Research – includes unfunded research effort, peer review of manuscripts, proposal preparation for competitive awards
* Administrative or University service – administrative assignments such as Dept. Chair, institutional committees, advisory boards
* Public service on behalf of the University
* Unpaid service to professional organizations or societies related to one’s field of work
* Activities over and above the individual’s job requirements, such as overtime or faculty overload.
* Compensation for external consulting, serving on external boards, and other types of professional work
* Volunteering as an individual for public service
* One-time, extra payments for special activities
* Other activities unrelated to responsibilities for the individual’s primary job
- Suitable Means of Verification is an employee evaluating effort on behalf of a terminated Suitable means of verification is an employee evaluating effort on behalf of a terminated or otherwise unavailable employee. The person verifying must be knowledgeable of the subject employee’s work such that validation of time spent on reported projects is appropriate. The verifying person must be the employee’s superior.
- A Principal Investigator (“PI”) is defined as the individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the Sponsored Project (grant or contract) including programmatic reporting.
- “Sponsored Projects” are defined as externally-funded activities in which a formal written agreement, i.e., a grant, contract, or cooperative agreement, is entered into by the University and by the sponsor. A sponsored project may be thought of as a transaction in which there is a specified statement of work with a related, reciprocal transfer of something of value.
- POLICY STATEMENTCertifications of Effort on Sponsored Projects are required for every University employee whose salary or wages are directly charged to a Sponsored Project account or whose salary or wages are used as cost sharing for a Sponsored Project. Individuals must account for 100 percent of activities which are part of their IBS.
- POLICY STANDARDS AND PROCEDURES
- Effort Certification
As a condition to receive federal funding, institutions must maintain records that are supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The University’s Effort Reporting system assures external sponsors that funds are properly expended for the salaries and wages of those individuals working on the project they sponsor. It provides the principal means for certifying that the salaries and wages charged to Sponsored Projects are consistent with the effort contributed.
- Employees required to certify under this policy are:
- Every employee whose salary or wage is directly charged to a Sponsored Project account (i.e. contracts or grants).
- Every employee whose salary or wage is used as match/cost sharing for Sponsored Project account.
- Federal regulations (OMB A-21 and Uniform Guidance, 2 CFR 200) outline different reporting requirements for salaried employees than for hourly wage earners.
- Salaried Employees
Salaried employees include, but are not limited to, faculty, professional & salaried staff, graduate and postdoctoral fellows, graduate and postdoctoral researchers, and all exempt employees.
- Hourly Wage Earners
Hourly wage earners include, but are not limited to, miscellaneous wage and bi-weekly employees.
- Hourly wage earners who receive pay from Sponsored Projects shall complete a time sheet recording their hours of work according to the terms of the Sponsored Project, but 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.
- Salaried Employees
- Reporting Periods
- The University divides each year into three (3) effort reporting periods: two (2) apply to all salaried employees who are required to report effort and one (1) 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 nine (9), ten (10), or eleven (11) month contracts, or during the six (6) month period from September through February for all other employees.
- The spring reporting period covers activities occurring in the spring semester for nine (9), ten (10), or eleven (11) month employees, or during the six (6) 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 shall use the Effort Reporting System to produce web reports for review. The reports shall list effort commitments made by the individual to individual projects and shall provide data to show how the individual’s salary charges were allocated for the reporting period. Salary allocations are not dictated by effort commitments. The distribution of salary payments as shown on the effort report, may or may not coincide with the amount of effort actually performed. Upon review of the record, if salary allocations are not representative of actual effort performed, the allocations shall be adjusted to be accurate. 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 shall be processed according to the University’s policy regarding cost transfers. A journal voucher must be submitted to correct the allocation of salary and to reflect true percentages of effort.
- The effort reported shall 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 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 of this Policy. Effort reports are not guided by the planned allocation of salaries, which may not reflect actual effort performance.
- Completed Effort Certification Revisions
Rarely, a revised effort report may be created to allow for an updated/revised version of an individual report which had already been certified and completed. Only the Research Office may create revised effort reports, and doing so requires a written request including a justification. Reports created for approved revisions must be completed within 30 days following approval. Revisions requested to remove unallowable charges from Sponsored Projects shall always be approved. If a revision is needed in order to remove a salary cost over-run from a Sponsored Project, then the charges shall be required to be transferred to a non-sponsored account as cost-share.
- Roles and Responsibilities
- Research Office
The Manager of Financial Compliance in the Research Office is responsible for ensuring that the University’s effort reporting system is compliant with federal government requirements and University policies. The Research Office has ten (10) days following the posting of a reporting period’s ending salary transactions to produce and release the reports to Departmental Effort Administrators. Electronic copies shall be retained by the Research Office, as required by sponsored agreements, usually three (3) 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 shall have one staff member assigned as the Departmental/Unit Effort Administrator. The Effort Administrator’s role is to facilitate the timely and accurate completion of their department’s effort reports. They shall be 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 sixty (60) days following the release of the reports. They shall also be responsible for requesting omitted reports when needed so that required reporting is accomplished for all employees.
PIs who are involved in the allocation of salaries and wages to Sponsored Projects must understand the importance of effort reporting compliance as it relates to their obligations of proper grant management. Effort certification is a requirement of accepting federal awards. PIs shall 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, to avoid over-committing themselves. They shall 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 Projects.
- Internal Audit
UD Internal Audit shall conduct independent evaluations of the Effort Reporting System as prescribed by OMB Circular A-21 or Uniform Guidance.
- Research Office
- 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 is not typical for a faculty member to be 100% grant-funded.
- Knowingly certifying a false effort report is a violation of University policy and may result in potential disciplinary action and civil or criminal penalties. 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 in the report.
- Documentation of suitable means of verification must be retained in the department as backup to support the certification by anyone other than the employees themselves. The retention period of this documentation should be in alignment with the required retention period of the award from which the individual was compensated.
- Employees required to certify under this policy are:
- Effort Certification