Last Update: June 2014
Responsible University Officer:
- Vice President for Research
- Associate Vice President for Research Administration
- Updated: June 2014
- Primary Contact : David Hagen
Printed on: . Please go to http://policy.umn.edu for the most current version of the Policy or related document.
Faculty and staff who are paid on sponsored projects, or companion cost share accounts, must certify the accuracy of this time (i.e., effort) according to the procedures established by the University.
All faculty, as well as all non-faculty who are serving as principal investigator (PI), must certify their own effort. Other non-faculty personnel, such as professional staff, senior fellows, and lab technicians, may certify their own effort or the PI or other responsible official(s) may certify their effort using suitable means of verification that the work was performed.
For all faculty, as well as all non-faculty who are serving as Principal Investigator (PI):
- The effort statement must reasonably reflect the time for which the PI is compensated by Institutional Base Salary, including time spent preparing proposals. Therefore they cannot typically certify 100% effort on sponsored projects unless they are on sabbatical from their teaching, outreach and administrative duties.
- PIs must certify at least 1% effort during at least one effort cycle per year to accurately reflect their leadership of the project. This requirement does not apply to co-PIs or other senior researchers. If there are multiple PIs, then at least one individual assuming responsibility for the scientific and administrative direction of the project during that effort cycle must fulfill the 1% obligation. This requirement does not apply to equipment and instrumentation grants, dissertation and training grants or other awards intended as "student augmentation," and limited purpose grants such as travel grants and conference support.
- Before principal investigators or key personnel reduce their effort by more than 25%, they must review the terms and conditions of their award to determine whether or not prior approval is required from the sponsor. If sponsor prior approval is required, a request must be submitted through Sponsored Projects Administration.
PIs have the responsibility to ensure that the effort of all individuals working on their sponsored project is certified in compliance with this policy. If an employee's effort is not certified on a particular project, the PIs department must remove salary and fringe benefit charges from all sponsored projects on which the individual is paid during that effort period. The department must move these charges to the project's non-sponsored default account and it cannot be counted toward cost sharing commitment (charges that are unallowable on the sponsored account are unallowable as cost sharing).
REASON FOR POLICY
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. These records must reasonably reflect the total activity for which the employee is compensated, encompassing both federally assisted and all other compensated activities on an integrated basis, not exceeding 100% of the Institutional Base Salary. In compliance with this requirement, the University has established a system for reporting the percentage of time (i.e., effort) that employees devote to federally sponsored projects. The University has chosen to apply this standard to all sponsors.
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 projects they sponsor. It provides the principal means for certifying that the salaries and wages charged to sponsored projects are consistent with the effort contributed. All employees involved in certifying effort must understand that severe penalties and funding disallowances could result from inaccurate, incomplete, or untimely effort reporting.
Finally, sponsors and auditors must also be able to verify that committed cost sharing has been provided. The effort reporting system is the mechanism the University uses to document cost shared salary expenses.
There are no appendices associated with this policy.
FREQUENTLY ASKED QUESTIONS
- Cost Sharing
- The amount of project costs not borne by the sponsor. The term includes cash contributions, in-kind (non-cash) contributions, and matching funds.
- Committed Cost Sharing
- Mandatory or voluntary cost sharing that is pledged in the proposal budget, budget justification, or stated in award documents.
- Mandatory Committed Cost Sharing
- Cost sharing required by the sponsor as a condition for proposal submission.
- Voluntary Committed Cost-Sharing
- Cost sharing not required by the sponsor as a condition for proposal submission but offered the sponsor by the University (e.g., in a proposal or other communication.) Upon receipt of an award based on that proposal (whether or not the agency calls out the cost sharing), the cost-sharing becomes an obligation that must be fulfilled.
- Voluntary Uncommitted Cost-Sharing
- Voluntary cost sharing not pledged in the proposal and subsequently not stated on award documents. This type of cost-sharing is not tracked (e.g., in a cost-sharing account) nor included as project-related effort in the investigator's effort statement. Instead, that effort becomes part of the investigators non-sponsored activities for the University. Note, however, that if a PI chooses to use voluntary uncommitted cost-sharing to fulfill sponsor requirements (such as to meet a required effort obligation), then this must be treated the same as voluntary committed cost sharing.
- The proportion of time spent on any activity and expressed as a percentage of the total professional activity for which an individual is compensated by Institutional Base Salary. Total effort for an employee must equal 100% a margin of error of one percent (+/- 1%) is acceptable due to rounding).
- An individual's total time compensated by Institutional Base Salary serves as the basis for determining their total effort. In other words, if an individual who is being compensated for a 100% appointment works 60 hours in a week, then 30 hours would represent 50% of their professional effort. If the same individual only works 40 hours in a week, then 20 hours represents 50% of their professional effort. If an individual who is being compensated for a 50% appointment works 30 hours in a week, 30 hours would represent 100% of their professional effort. If the same individual only works 20 hours in a week, then 20 hours represents 100% of their effort. If a graduate student is employed for a total of 10 hours per week, then 5 hours represents 50% of their effort.
- Effort Coordinator
- Effort reporting administrators at the Department level who facilitate the distribution and submission of Effort Statements.
- Historical Salary Adjustment (HSA)
- An adjusting or correcting internal accounting transaction to transfer salary and fringe charges from past pay periods from one chart string to another.
- Institutional Base Salary
- The base annual compensation set by the University for an employee. It includes salary increments, augmentations and paid overtime. It does not include non-service or one time payroll items, such as awards and overload payments, nor does it include compensation for patient care activities provided through the University of Minnesota Physician (UMP) practice plan that are paid through the University's common paymaster.
- Non-Service Payroll
- All non-activity based payroll items which appear in gross earnings for eligible employees and are not to be included when certifying effort. Non-service payroll includes employee benefit accounts, trainee job class codes, overload payments, bonus payments, balance sheet labor clearing accounts and unused vacation payouts.
- Notice of Grant Award (NOGA)
- A document that provides information regarding the award's important terms and conditions. It should be referred to by PIs and departments to provide guidance in managing the project.
- Overload Payments
- Payment for professional activities that exceed the normal scope of the individual's appointment. These payments are usually paid hourly or by lump sum, for activities such as advising, consulting, article writing, course development/revision, translations, teaching, lectures, special task/force/focus group etc.
- Preaward Costs
- Costs incurred prior to the start date of an award or a budget period.
- Retroactive Pay
- Pay received for work performed in prior pay periods.
- Senior Researcher
- Principal investigator without faculty rank.
- Sponsored Project
- An externally funded activity that is governed by specific terms and conditions. Sponsored projects must be separately budgeted and accounted for subject to terms of the sponsoring organization. Sponsored projects may include grants, contracts (including fixed price agreements), and cooperative agreements for research, training, and other public service activities.
- Work Study
- A Financial Aid program in which the state or federal government pays a percentage of a student's wages.
- Principal Investigator
- Ensure the appropriateness and accuracy of all effort expended on the sponsored project and compliance with Effort Policy. Expend effort on project. Certify direct-charged and committed cost-shared effort up to the effort level committed. On federal projects, obtain prior approval if absent for more than three consecutive months, or effort is reduced more than 25% from the budgeted awarded plan.
- Certify effort on a timely basis.
- Communicate issues or errors to department effort coordinator/payroll accountant.
- Research Employees
- Consult with PI to determine who will certify effort for the individual researcher. If not PI, then certify effort on a timely basis. Communicate issues or errors to department effort coordinator / payroll accountant.
- Unit Administrator
- If committed cost sharing information is not listed or listed incorrectly on the NOGA, forward the information to the SPA grant administrator.
- Effort Coordinator
- Facilitate the department effort certification process. Ensure process is managed so that all parties have adequate time to complete certification and effort statements are completed (Certified and Approved, or equivalent status) within the given timeframe. Review and approve every effort statement to ensure it is accurate. Responsible for the timely completion of the effort statements and for the communication of policy and procedure regarding effort certification to everyone in their department who is involved in the process.
- Departmental Payroll Administrator
- Responsible for entering payroll-related data into the University's payroll system. If data is inaccurate on an effort statement, this individual is responsible for entering the correctional transactions in the payroll system in a timely manner.
- Certified Approver
- Responsible for approving historical salary adjustments that are made after the effort certification cycle has been completed, and approving the request to recertify the effort.
- Department Head
- Establish effective processes and controls that will ensure compliance. Assign an Administrator and/or Effort Coordinator to oversee the certification of effort. Provide local oversight and take action when notified of delinquent effort reports. Approve recertification requests.
- Grant Administrators, Sponsored Projects Administration
- During award setup, confirm that committed cost sharing is documented on the NOGA as a condition of the award.
- Effort Unit, Sponsored Projects Administration
- Develop and implement effort reporting policies and procedures. Assist with development of educational programs for all employees involved in the effort certification process. Ensure that the effort system produces accurate effort statements in a timely manner. Monitor system to ensure compliance. Monitor the effort process for timely submission and report findings to departments.
- Certifier & PI Tutorial
- Certifier Job Aid
- PI Job Aid
- ECRT Training Manual for Effort Coordinators
- Training & Organizational Development
- OMB Uniform Guidance
- December 2014 - References to A-21 changed to OMB Uniform Guidance in Related Information.
- June 2014 - Comprehensive Review. Minor Revision. Changes made to clarify that each faculty member, not only faculty who are PIs, must certify their own effort. It also specifies that the "at least 1%" effort must be recorded during the year, vs. during the grant period. The policy now provides a new template for documenting unpaid activities, or paid activities when ECRT does not accurately reflect the paid activities.
- June 2008 - Made changes to reflect EFS implementation.
- February 2004 - Revised policy and procedures to reflect use of new Effort Certification and Reporting Tool (ECRT).
- October 2003 - Added link to 9 Over 12 Payroll Adjustment Worksheet. Added clarification for certifying effort and charging travel costs.
- July 2002 - Clarified departmental staff responsibility for notifying SPA Effort Unit of changes to committed cost share information. Reinforced faculty/staff requirement for certifying direct-charged and committed cost shared effort up to the total effort level commitment. Clarified certification requirements for Unpaid Effort. Reinforced PI responsibility to obtain sponsor prior approval to any change to committed cost sharing during projects.
- July 2001 - Added definitions for committed and uncommitted cost sharing, and mandatory and voluntary cost sharing. Changed prior requirement for quarterly PI 1% minimum effort reporting to mandate that such effort can be provided at any time within the year (i.e., academic year, summer months, or both), effective 1/5/2001. Effective 1/5/2001, eliminated requirement that faculty, or principal investigators without faculty rank, certify voluntary uncommitted cost sharing.
- December 2000 - Updated to reflect the use of the "Historical Salary Adjustment" rather than the discontinued "Type 38 Payroll Journal Voucher".
- September 2000 - Deleted reference to obsolete Sponsored Projected Employee Verification Statement. Clarified who is authorized to make changes to the statement.
- June 1999 - Clarified Policy Statement, Reason and Updated Related Information, Special Situations, Definitions, Responsibilities sections and all procedures. Added new procedure: Generating Departmental Effort Statements. Eliminated references to ORTTA within policy because of reorganization.
- July 1997 - clarified the definition of "effort" for exempt and nonexempt employees; stated the requirement for Principal Investigators to certify effort; included the requirement for the certifier to initial changes made to the effort column prior to certification; clarified who can certify effort statements.
- May 1996.
- September 1995
- Effort Reporting Policies and Procedures - Executive Summary.