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 else the PI or other responsible official(s) must 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 award. 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 award during that effort cycle must fulfill the 1% obligation.
- 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, the PI must submit a request 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 PI’s 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).
The requirement that a PI must certify at least 1% effort 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, or in special circumstances receiving written approval from the Associate Vice President for Research Administration.
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.