Effort Certification Policy dated December 10, 2014
Provost & Vice President for Academic Affairs
Facilities and Administrative Cost Recovery and Distribution Principal
Investigator Eligibility and Assurances Policy
Export Control Policy
Frequency of Review
Date of Revision
Effort Certification is required for every University employee, including students, whose salary or wages are either directly charged to a Sponsored Project or whose salary or wages are allocated as cost-sharing for a Sponsored Project. Please see Section IV below for the definitions of capitalized terms in this Policy.
II. Policy Statement
The purpose of this Effort Certification Policy ("Policy) is to ensure that compensation in connection with University Sponsored Projects complies with federal regulations as defined in the Office of Management and Budget (0MB) Uniform Guidance (2 CFR 200.430). Failure to comply with federal regulations regarding compensation could jeopardize future Sponsored Projects and could result in penalties and damage to the University's reputation and integrity.
The University must ensure that salary and wages charged to a Sponsored Project are based on accurate records of the work performed. Charges to Sponsored Awards for salaries and wages are typically allocated according to planned effort that must be reviewed retrospectively (at the end of the Sponsored Project) to determine if the actual effort differed from the planned effort. The University provides this assurance by requiring Effort Reports for each individual whose salary and wages are charged to one or more Sponsored Projects during an effort-reporting period.
IV. Methods of Certification
Effort Certification Reports must be performed in an accurate and timely manner in order to confirm that salary charges are accurate, allowable, and were truly allocated in accordance with the effort actually performed by an individual. The two methods of certification are described below.
A. Time Sheets for Hourly Wage Earners
Employees, such as students, and nonexempt employees, whose salary or wages are dependent on submission of a time sheet will not be required to certify a separate Effort Report if the time sheet includes (i) the actual hours worked with dates on which work was performed, (ii) the Sponsored Project(s) for which the work was performed, and (iii) the approval of someone with suitable means of verification that the work was performed: For suitable means of verification to be achieved, the person certifying the work on behalf of another employee must be an employee of the University and be able to represent a relationship with that employee which would afford them reasonable knowledge to testify to that employee's work. In other words, they must have first-hand knowledge of the employee's effort. Examples of suitable approvers might include a supervisor, project PI, or faculty advisor. OSRP will periodically audit time sheets for compliance.
B. Effort Reports for Other Employees
Quarterly Effort Reports will be required for employees who do not certify effort by the time sheet method. Each Effort Report must account for 100% of the activities that were supported by the employee's institutional base salary (IBS), and any additional compensation that may have been paid from a Sponsored Project.
Effort Reports will also be used to confirm that effort performed was at least equal to any levels of effort committed to Sponsors on contracts or grants. While it is not a requirement to meet an individual effort commitment in every reporting period, it is expected that an effort commitment will be met on average during each budget period (or year) in which a Sponsored Project is active.
Each Effort Report will require suitable means of verification certification by a responsible person who is in a position to evaluate the employee's full workload as described in IV (a)(i) above.
1. Procedures for Effort Reports
The University will produce Effort Reports quarterly to certify effort performed in the previous three months. Each fiscal year will include four reporting periods as follows:
Period 1: Activity performed June through August
Period 2: Activity performed September through November
Period 3: Activity performed December through February
Period 4: Activity performed March through May
After the end of each reporting period, OSRP will obtain salary distribution information and produce draft Effort Reports for employees who received funding from Sponsored Projects or who had commitments on Sponsored Projects during the applicable reporting period. The OSRP will distribute Effort Reports to responsible people in the departments for review and signatures. The Effort Reports must be certified, returned to the OSRP and reviewed by OSRP within 90 days following the end of the reporting period.
Percentages of effort, which are provided on the Effort Report, will be calculated based on the employee's actual payroll distributions for work performed during that period. The Effort Report will list committed effort amounts that are applicable to the effort period so that actual effort may be compared to committed effort. Commitments made in a proposal become binding when the Sponsored Project is awarded and must be tracked and reported. Effort commitments may be fulfilled either by charging a Sponsored Project directly or by cost sharing. After a retrospective review, if the actual percentages of effort reported are determined to be inaccurate, the numbers must be corrected, and accounting adjustments must be made to align salary charges with actual effort performed.
When the reviewer is satisfied that the Effort Report is accurate and complete, he or she will certify the Effort Report. A percentage may be considered accurate if it is within five percentage points of what the certifier believes to be true. For example, if an Effort Report indicates that 50% of the employee's time was spent on a particular project, certification would be appropriate if the actual effort performed was anywhere between 45% and 55%, and no accounting adjustments would be required.
In rare circumstances, a revised Effort Report may be created to over-ride an existing Effort Report that had already been certified and completed, if the original is determined to be in error. Revised Effort Reports must clearly indicate that they are revisions and must include adequate justification to explain the need for a revision. The same requirements for certification that apply to original Effort Reports will apply to revised Effort Reports. Original Effort Reports must be maintained as support for revised Effort Reports.
Knowingly certifying a false report could potentially result in civil or criminal penalties for fraud.
It will be the responsibility of the OSRP to maintain Effort Report documentation in accordance with University policies and Sponsor policies.
Actual Effort: the amount of actual effort performed, when considered in retrospect. Since salaries are typically allocated according to planned effort, initial allocations must be reviewed retrospectively to determine if the actual effort differed from the planned effort.
Committed Effort: Any quantified amount of effort offered by a PI, co-PI or other personnel named on a sponsored project.
Cost-Shared Effort: Cost-shared effort is that effort which is directly allocable to a Sponsored Project, but which is financially supported by the University or third party entity rather than a Sponsor.
Effort Report: A complete report of an individual employee's effort on all activities included in his or her institutional base salary (IBS) during a specified time period.
IBS (Institutional Base Salary): IBS is an employee's total compensation by the University for activities described in his or her offer letter or contract with the University. These activities may include duties in categories such as instruction, research, administration, or service. Payments for services performed outside of the duties for which one was hired are not included in the IBS. Payments outside of the IBS might include compensation for activities over and above the individual's normal job requirements, such as overloads, overtime, bonuses, commissions, external compensation for consulting or other types of professional work, volunteer work as an individual rather than a representative of the University, extra payments for special activities that are non-recurring, or any other activities which are not related to the responsibilities for the individual’s primary job assignment. Most types of stipends are not included in the IBS, but stipends for department chairs are considered part of the IBS if stipulated in their offer letter or contract. There could be a ceiling imposed on this IBS calculation by statute.
Non-sponsored Activity: Are activities included in an employee’s IBS, which are not funded by a Sponsor outside of the University. Most faculty members will have responsibilities that must be supported by non-sponsored (or University) funding. These may include administrative duties, typical course development and instruction, service on internal or external boards or committees, proposal writing unless for non-competitive grant renewals, peer review of manuscripts, fundraising and lobbying.
OSRP: The University Office of Sponsored Research and Programs.
Percent Effort: the proportion of an employee’s workload spent on a Sponsored Project, expressed as a percentage of that employee’s total workload. An employee’s total workload will always equal 100% regardless of appointment type, contract length, or the number of hours spent working.
PI: The principal investigator or individual designated by the University to have the appropriate level of authority and responsibility to direct a Sponsored Project.
Sponsor: The organization or funding agency that funds a Sponsored Project.
Sponsored Project: An externally funded activity in which a formal written agreement such as, a grant, award, sub-award agreement, cooperative agreement, contract, or fellowship is executed between the University and a Sponsor.
University: Arcadia University, its colleges, schools, affiliates, divisions, and subsidiaries.
VI. Effective Date
The Effective Date of this Policy is the date that it is signed by the President.