Effort Certification

Questions about the Effort Certification Statement

1. One or more of the lines on the effort certification statement is displaying the text "? CAP" in red. What does this mean?

   This is an NIH Salary Cap warning message indicating the account on which the employee was paid is an NIH sponsored project, and that their salary may have exceeded the current NIH salary cap. The difference between the employee's salary and the NIH salary cap must be cost-shared.

   A checkmark with the word "CAP" in green also indicates that salary was paid on an NIH sponsored project, but ECRT has determined that the cap has not been exceeded.

   Please refer to the "Salary Cap Payroll and Cost Sharing Calculations" job aid for more information about the NIH salary cap.

2. ECRT displays the payroll, cost share and computed effort columns in hundredths. Why are only whole numbers allowed in the certified effort column?

   The first three columns reflect a calculation (computed effort) that is based on actual payroll dollars. Providing the payroll information in hundredths enables reconciliation of the effort statement with payroll reports. However, the University has determined that certifying actual effort provided at such a fine level of detail is unnecessary and, in most cases, unrealistic.

3. When is it necessary to correct effort on an effort statement?

   It is necessary to correct an effort statement when there is a 5% or more variance within one's total effort. The federal government recognizes that a precise assessment of effort is not always feasible, nor is it required. Therefore, the University has determined that actual effort can differ from certified effort by less than 5% without noting a change. For example, a correction would not be necessary if an employee's effort statement shows 25% of effort being expended on a grant and the employee felt their actual effort was 21%. However the statement must be adjusted if that person believed their actual effort was 19%.

   Please note that this is not the same thing as saying that certified effort can vary from actual payroll charges by 5%, nor that you may exceed the NIH salary cap by 5% (see link to NIH Salary cap job aid mentioned above for more information). Certified effort on an individual sponsored project line must equal computed effort (payroll plus cost share), within a one percent variance to allow for rounding. Also, please remember that when effort is reduced by more than 25% from the level approved by the agency at time of award or as subsequently approved by the agency, agency approval is normally required. Note that simply listing a different level of effort in an agency progress report does not constitute formal agency approval for this purpose.

4. Is there a way to certify all accounts on an effort statement without having to check each of the "certify" checkboxes?

   Yes. The check box located in the lower right hand corner of the effort statement on the line labeled “Grand Total” acts as a toggle to check or uncheck the boxes on all of the lines on the statement.

5. Do I need to print out effort certification statements for auditing purposes?

   It is not necessary to print out effort certification statements from the ECRT system. The electronic statements, including all attachments, will be retained for audit purposes.

Questions about the Certification Process and Using ECRT

1. I am an effort coordinator, and I am not sure why certain employees are showing up in my Department Dashboard list.

   The Department Dashboard includes effort statements for all employees who are associated to the DeptID through their primary appointment and were paid or cost shared from grants within that department, as well as effort statements of employees whose primary appointment is not in that DeptID but the individual was paid from or cost shared to a grant within the effort coordinator's department. The former are listed under the Department section. The latter are listed under the Non-Department section. It is important to coordinate with other effort coordinators when it is unclear which effort coordinator will be approving a statement.

2. How does a supervisor or lab/project supervisor certify a researcher's effort?

   ECRT allows either the researcher or the Principal Investigator (PI) to certify the researcher's effort. Other responsible officials with suitable means of verification, such as lab/project supervisors, may also be appointed as a Designee of the PI to certify the effort of researchers who are working on a specific project. To allow them to do so, the effort coordinator should complete the Designee Form and submit it via email to [email protected]. The effort coordinator will be notified once the Designee relationship to the project has been made. Only one Designee per EFS project can be established.

3. Can multiple Principal Investigators certify a researcher's effort?

   Yes. To certify specific project(s) on an effort certification statement, check the "Certify" checkbox for the specific project(s) for which you have suitable means of verification, and then click the "Certify" button.

   All account lines (including non-sponsored accounts) must be checked and certified for the effort statement to be considered complete. The transaction history indicates who certified a specific account.

4. Is there a way to indicate whether the researcher or the Principal Investigator should certify the researcher's effort?

   In the ECRT system, there is no way to indicate whether a researcher should certify their own effort, or the principal investigator should certify the researcher's effort. University procedures allow either individual to certify. The researcher and their principal investigator will need to communicate outside of ECRT to decide who will certify the researcher's statement.

5. I am an effort coordinator and I also have my own effort to certify. Can I certify my effort and approve the statement too?

   No. To avoid having the same person certify and approve a statement, ECRT does not allow an effort coordinator to certify any effort statements, including their own. It is uncommon for an effort coordinator to be paid from a sponsored project, but accountants are occasionally paid from large center grants or other large projects. If the accountant is also the department’s effort coordinator, then the principal investigator of the project, or their Designee, must certify the statement.

6. I know that a researcher should have an effort statement to certify but I cannot find it. What do I do?

   Any number of situations could account for a missing effort statement. You should first confirm that the researcher's payroll was charged to the project or an associated cost share account string. This can be determined by reviewing the individual's Salary Distribution Report. If the Salary Distribution Report indicates the individual was correctly charged to a project within your department, but the individual does not appear on your Department Dashboard, please contact the central effort unit staff.

7. Can I re-certify my effort statement before the certification period ended?

   Within the effort certification period, you can re-certify the statement in ECRT but you will need to contact your effort coordinator to request that the statement be re-opened. You should document the reasons for the changes in the "Effort Notes" section of the statement so that appropriate changes to payroll and cost sharing can be processed by your effort coordinator or payroll administrator. All certifications should be completed prior to the due date as late certification is a compliance issue that federal auditors may review in their audits of University grants administration.

8. Can I re-certify my effort after the certification period ended?

   The ECRT system allows re-certification of an effort statement at any time. After the certification period has ended you will be required to document the reason for the recertification by including a letter that is signed by the Principal Investigator, Department Head and Certified Approver. Additional review and approval will be required centrally and the re-certification may be denied. Re-certifications should occur only under very rare circumstances and re-certifications that involve moving salary onto a sponsored project are closely scrutinized prior to approval due to their high audit risk. Please coordinate any recertification of effort with your effort coordinator.

9. How should certification be handled when a researcher works on sponsored projects for more than one PI? 

   If the researcher is also a faculty member, then that individual should certify their own statement. If a non-faculty researcher’s statement includes sponsored projects belonging to more than one PI, then each PI will have access to the effort statement and each may certify the researcher’s effort on their own project. 

   If there is also non-sponsored effort on the statement, then either of the PI’s or an effort coordinator could consult with the researcher, or with the researcher’s supervisor(s), and leave a note on the effort statement documenting the discussion and confirming the accuracy of the non-sponsored effort. With such documentation, either PI can reliably certify the entire statement. The individual researcher also has access to their own effort statement and could be asked to certify their own effort statement.

Questions about Cost Sharing

1. How can I modify existing cost sharing, or add a new cost sharing account line in the ECRT system?

   Cost sharing that appears on the effort statement can only be changed or added through the HR payroll system. The original payroll transactions and Retroactive Distributions (Retros) are the only means for ECRT to load information into an effort statement and calculate the percentage of cost share onto a project and the percentage from a program. Salary distributions should be reviewed regularly and changed to reflect future distributions of effort. Retros will be required to make changes to payroll and cost sharing distributions that have already occurred. Costs that are moved onto a sponsored project more than 60 days after the original charge was incurred are considered late cost transfers and require approval by a Certified Approver.

2. How should uncommitted cost sharing be certified?

   Uncommitted cost sharing does not need to be certified. Only committed cost sharing requires certification. Please note that any salary paid in excess of the NIH salary cap is considered committed cost sharing which must be certified.

Questions about Special Payroll Circumstances and Certifying Effort

1. How are 9 over 12 appointments handled?

   Currently, the ECRT system does not handle effort certification for faculty with 9-month appointment terms when 9-month pay is spread over 12 months (9 over 12 appointments). Certification must be processed as a manual statement and attached to the electronic effort statement. Please see the Training Materials for 9 Over 12 calculations on the Effort Reporting Training page for more information.

2. How are bonuses and other lump sum payments handled?

   These payments are not part of the Institutional Base Salary and, therefore, are not certified. If the correct earnings code was used for the payment, ECRT will not include those earnings.

3. Do I certify payroll for an augmentation?

   Yes. An augmentation is typically paid when an individual assumes additional responsibilities for an entire appointment year. For example, a professor’s salary may be augmented while acting as a department head. Augmentations are part of the Institutional Base Salary and the related effort must be certified.

4. How do you handle people who have two rates of hourly pay?

   Currently, the ECRT system does not handle two rates of hourly pay. If an individual is being paid two rates of pay for multiple appointments, then a manual effort statement will be needed in most cases. Please see the ECRT job aid on multiple rates of pay.

5. How is overload pay accounted for?

   Overload payments are typically paid as a lump sum for a short term activity and are not considered to be part of the Institutional Base Salary. Therefore, overload payments are not certified. If the correct earnings code was used for the payment, overload earnings will not be included on the effort statement.

6. How is retro pay handled in ECRT?

   Retro pay is not the same thing as a Retroactive Distribution. As noted above, the latter is a mechanism to move a payroll distribution that has already occurred. Retro pay is earnings that are being paid to the individual for a prior pay period (i.e. late pay). Retro pay is included in ECRT. However, because retroactive earnings are not assigned to the prior payroll period in the payroll system, ECRT is not able to assign the retro pay to a prior effort period. If the retro pay was received for work performed in a prior period of performance, then the current effort statement may be incorrect. Please see the ECRT job aid on retro pay.

7. How is overtime pay handled in ECRT?

   Overtime payments to civil service and union-represented employees for hours exceeding the normal workweek (40 hours) must be certified and those earnings are included in ECRT. However, overtime pay may skew the effort statement and require a manual effort statement. It should be noted that some sponsors are unwilling to pay for overtime premium costs. If this is the case, the overtime pay will have to be charged to a cost-sharing chart string.

Effort Policy Questions

1. What time is included in "100% effort"?

   Faculty, P&A and V-class civil service positions: 100% effort is total time spent conducting University business irrespective of the normal work schedules. This includes work performed outside of the '9 to 5' work schedule, work performed during the evenings, weekends, while on vacation, off-hours, and on or off-campus. For example, if a PI works 30 hours per week on the "Future Cures" sponsored project and 30 hours per week on something else, “Future Cures” receives 50% effort.

   Positions paid hourly and subject to paid overtime: 100% effort consists of total hours worked including overtime. The effort is thereby measured (that is, work schedules are established) and documented by some form of continuous recordkeeping. For example, if a union lab technician works 40 hours a week on “Future Cures” and 10 hours a week on something else, “Future Cures” receives 80% effort.

   Graduate Assistants and students: 100% effort for graduate students in a bona fide employee-employer relationship consists of the sum total hours worked on their appointment(s). For example, 100% effort for a graduate assistant who has two 25% appointments would consist of the combined two appointments, or a maximum weekly base of 20 hours. Graduate students who receive stipends paid by training grants are typically appointed in non-service classifications and are not considered employees and therefore do not require effort to be certified.

2. Do I need to notify the sponsor if I change my effort on the project?

   Non-federal awards: it depends on the terms and conditions of the award. Contact the SPA grant administrator for instructions.

   Federal grants where you are the principal investigator: the 25% rules applies. Prior approval from the federal sponsoring agency is required if principal investigators or project directors will be disengaged from the project for more than three consecutive months, or will reduce their effort by more than 25 percent from the level of effort approved at the time of award, or subsequently approved by the sponsoring agency. Indicating a different level of effort in a progress report does not constitute "subsequent approval by an agency" for this purpose. Note: some agencies, e.g., NIH, extend this rule to all key personnel listed in the notice of grant award. When this situation exists, the principal investigator must write a letter to the federal grant/contracting officer addressing the following:

   • How does the reduction affect the work scope?
   • If this represents paid effort, how will the funds be re-budgeted?

   The letter must be signed by the principal investigator, unit head (or dean, if appropriate) and endorsed by SPA. The grant administrator in SPA should be contacted for questions.

3. What do I certify if I consulted on a project but I am not a regular employee on the project?

   This intra-University consulting fee payment is a type of overload payment. See the job aid for overload payments for instructions on handling this situation.

4. What do I record regarding the principal investigator's effort?
   • Effort of 0%: This is permissible only if (1) the award is for equipment/instrumentation, dissertation and training grants, or other award intended as a “student augmentation”, and limited purpose grants such as travel and conference support. This is also permitted for individuals names as principal investigators or $0 Master Agreements (effort must, however, be certified on actual activities funded under the master), or (2) the principal investigator recorded at least 1% effort during one of the other effort periods during the year.
   • Effort over 1%: Record actual percentage of effort
   • Effort of 100%: This is not typically permitted. Principal investigators cannot work 100% on a grant unless they are on sabbatical or other leave from their teaching and other services duties, and have only de minimis administrative duties.

5. Can I incur travel expenses on a grant but not certify effort if I didn't work on the project during that effort period?

   If the traveler is not providing effort to that project during that effort period, it is then dependent on the traveler's role on the project and how federal regulations must be applied:

   • If the traveler is a principal investigator or a senior researcher: Yes, the effort can be uncommitted cost sharing, which does not require certification.
   • If the traveler is an employee with a full time (100% appointment) on another project: No. Travel expenses on a sponsored project are permitted only if the employee contributes effort to that project. The effort must be certified or cost shared to the project during the effort period in which the travel occurs.
   • If the traveler is a trainee or an employee with a part time (less than 100% appointment): Yes. If the principal investigator has determined this travel is necessary for the project, travel expenses may be incurred against the project for activity or travel that occurs outside of the University appointment. The effort does not require certification but it does require documentation in the comments section of the expense reimbursement document such as: "This travel and related activities occurred outside of my University appointment time."
   • If the traveler is a student who is not an employee or a trainee: Yes. Justify the expenses according to the justification standards and include a statement that indicates that the student travel is done on a volunteer basis.

6. Cost sharing is not allowed on pre-award accounts in EFS. How do I certify cost sharing on a pre-award account?

   Since a pre-award account string is not yet an actual award, it is not possible to set up a cost share budget in EFS and, therefore, cost sharing cannot be charged to a pre-award account. Effort that is to be cost shared once the pre-award becomes an award must be directly charged to the pre-award account string so that the effort can be accurately certified. 

   After the award has been received the effort can be removed to a cost share chart string. At that time, if the source of the cost share already exists on the effort statement, then ECRT will automatically apply the transaction to the statement without reopening the effort statement. If the source of the cost share does not already exist on the statement, then re-certification will be necessary since the effort allocated among non-sponsored funding sources will change.

Questions about Summer Effort

1. Can I take a vacation during the summer and still charge the time to my sponsored project?

   If you are a faculty member on a nine or ten month appointment (formerly call a "B term” appointment), then the answer is generally "no". Vacations should be accounted for by reducing your total overall effort. For example, if you plan on taking a two week vacation during your summer appointment, then you should reduce your effort accordingly – either by reducing your effort throughout the duration of the summer appointment period (e.g, a two week vacation out of a 13 week appointment period = ~15%, so your paid appointment for the summer would be ~ 85% rather than 100%) or by taking the specific two weeks as unpaid time.

   If you are a faculty member on a twelve month appointment (formerly call an "A term” appointment) r, then your appointment allows you to take up to 22 days of paid vacation, and your labor distribution should reflect the same allocations as when you are working (e.g., if you routinely work 30% time on sponsored projects, those projects can legitimately pick up their proportionate share of the vacation costs). It is not appropriate to suddenly change your labor distribution percentages solely or primarily to force your sponsored projects to pick up more than their fair share of vacation expenses.

   This is really a fair compensation issue, not an "effort" issue per se. In other words, the University is in essence paying you only for time you are officially working or taking official, approved vacation as dictated by your appointment.

2. Can I spend time on University business (e.g, writing proposals or preparing for classes) but still charge 100% of my summer salary to my sponsored projects?)

   Possibly, if an offsetting percentage of time was paid for by the University during the same effort cycle elsewhere in the academic year. Faculty and departments have three charging options:

   1. It is always the best practice to charge your effort commensurate with the way it is being devoted. Thus, if you project you will devote 30% of your summer time working on proposal preparation (a cost that cannot be charged to your sponsored projects), it is best if you charge your sponsored projects 70% time and charge an allowable departmental fund source 30% time for the proposal preparation effort. This is beneficial both because it avoids any question an auditor might raise about why you were (for example) charging 100% of your salary to your NSF grant while you were busy writing your NIH proposal, and because, if your plans have to suddenly change, your salary is already appropriately charged.
   2. The federal rules do, however, permit a researcher to “average" their time over the effort cycle without requiring that you make salary adjustments for short-term (e.g., one or two months) fluctuations. Because our effort cycles now extend beyond the summer period, this means some averaging between summer and academic year appointments can occur, if desired. Thus, if during the course of a full effort cycle your appropriate sponsored projects time is (or will be) 70% and the appropriate University business percentage is 30%, the researcher may charge their salary that way for the entire effort period and is not required to make salary adjustments to cover short-term fluctuations in how effort was or will actually be devoted. The cumulative percentages must, however, turn out to be accurate when the effort cycle is certified.
   3. In this same example, the researcher could also legitimately charge their salary 100% to one fund source for 70% of the time covered by the effort cycle, and charge their salary 100% to another fund source for the rest of the effort cycle (30%). While permissible, this model is not ideal given the perception issues raised in (A) above, as well as the challenges involved in managing mid-course adjustments (see note below).

   NOTE: While the latter two charging options are permissible, faculty and departments need to be aware of the dangers of using these methods. Specifically, if their plans change during the effort cycle more than the 5% variance allowed, adjustments going back to the beginning of their effort cycle may be needed. It is possible that some fund sources will no longer be available by that time to charge their salary. For example, if a faculty member realized late in an effort cycle that the correct “split” of effort for that cycle was actually 80% to sponsored projects and 20% to the department rather than 70/30, but one of the grants had ended earlier in the effort cycle, that fund source would likely no longer be available to pick up its share of that extra 10%. It is also possible that an award, while still open for charging, doesn’t have the funds necessary to pick up that extra cost. Sponsored Financial Reporting will normally not “re-open” awards for which financial reports have already been submitted to allow extra charges. Instead, that grant's share of the extra 10% would have to be paid by an allowable departmental fund source (cost-shared). Other sponsored awards may not be charged to cover a deficit in another sponsored fund source. These problems can be avoided or minimized by either using Option (1) above or by regular (monthly or every other month) PI/departmental sponsored projects review and reconciliation activities to make sure that labor distributions for the full effort cycle remain accurate or are updated early enough so that historical salary adjustments are not needed.

3. Why don't I have to file an "Exception Form" any longer if I want to charge 100% of my summer salary to sponsored projects?

   Charging sponsored projects for effort as it is devoted remains the best practice (Option A in the question above). If this method is used, then faculty still need to take care that they not conduct other University business at the time they are charging sponsored projects for their time. It is appropriate for department chairs or others to verify with their faculty that charges to sponsored projects remain appropriate over the course of an effort cycle. However, because the University no longer has an effort cycle that is limited solely to the summer academic period, it is allowable for faculty to "average" their effort across the applicable portions of the academic year and summer appointments contained in a given effort cycle. This may result in an appearance that a sponsored project was charged 100% during the summer while University business was conducted; however, it will also be the case that there will be an offsetting amount of sponsored project effort devoted during the academic year while the researcher's salary was paid by the University. By the end of an effort cycle, the proportionate pay (direct charged or cost-shared) and effort are expected to be in balance.

4. Can I work off-campus and still charge my effort to a sponsored project?

   Faculty working from an off-campus location must have arrangements in place to communicate with students, staff and other co-investigators working on the same sponsored project(s), and they must be able to be reached by university and funding agency officials. Faculty must also have arrangements in place to maintain oversight over research activities and facilities supported by sponsored projects.