Effort Reporting Policy

Effective Date:

July 1, 2014

Supersedes:

Certification of Salary Distribution (Effort Reporting) Policy

Policy Review Date:

July 1, 2015

Issuing Authority:

Research Foundation President

Responsible Party:

Garrett R. Sanders, Executive Vice President

Contact Information:

518.434.7130

garret.sanders@rfsuny.org

Reason for Policy

Effort reporting is required by the U.S. federal government as part of the process to ensure and document that individual effort directly charged to federally-funded sponsored programs is accurate and reasonable in relation to the actual effort dedicated to the sponsored program.

The governing regulations are found in the Office of Management and Budget ("OMB") Circular A-21, "Cost Principles for Educational Institutions", Section J.10., and in OMB Memoranda 01-06, "Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs", January 05, 2001.

These regulations state that institutions receiving federally-funded sponsored programs must maintain systems and processes that document the distribution of activity and associated payroll charges to each individual sponsored agreement.

Statement of Policy

The RF must assure that the salaries charged or costs shared by principal investigators (PIs) and SUNY and RF employees to federally-funded sponsored programs are reasonable in relation to the actual work performed.

Method for Certification

The RF’s effort certification method is After-the-Fact Activity Records as defined by OMB Circular A-21, Section J.10.c.(2).

Whose Effort is Required to be Certified

The EFFORT of all RF and SUNY employees with salary charges that are reimbursed or unreimbursed (cost shared) to a federally- funded sponsored program must be certified.

Who Must Certify Effort

Principal investigators (PIs) must certify their effort and the effort of staff working on their federally-funded sponsored programs. The PI may delegate this responsibility to a designated proxy certifier who must have suitable means of verification.

When to Certify Effort

Effort statements must be certified in a timely manner after the statements have been reviewed by campus effort reporting administrators and released to certifiers. Certification should occur no later than 120 days after the end of the period of performance (i.e., the base effort dates), unless EXTENUATING CIRCUMSTANCES exist. If EXTENUATING CIRCUMSTANCES exist so that an effort statement cannot be certified in a timely manner campus effort reporting administrators must document the reason that certification required additional time.

Records Retention

Effort statements and the applicable documentation to support the certification must be retained in accordance with the RF Records Management Policy.

Responsibilities

The following table outlines the responsibilities for compliance with this policy:

Responsible Party

Responsibility

Principal Investigator

-Understand and apply the federal government, sponsor-specific, institutional, and RF requirements for effort reporting in relation to the sponsored programs lifecycle.

-Communicate with appropriate departments to ensure the accurate and timely processing of labor distribution adjustments, and the appropriate allocation of salary costs.

-Ensure that all information reflected on the effort statement (e.g., cost sharing) is accurate and reasonable in relation to the work performed; and make corrections as appropriate.

-Ensure that his/her own effort – and the effort of the other persons he/she is responsible for – is certified accurately and timely.

Monitor the charging of salary on sponsored agreements to ensure appropriate costing criteria is applied.

Various other campus roles (e.g., deans, provosts, department chairs/directors/administrators, institutional officials, operations managers, vice presidents for research) depending on the campus specific structure

-Understand and apply the federal government, sponsor-specific, campus, and RF requirements for effort reporting in relation to the sponsored programs lifecycle.

-Review the establishment of salary charges, cost sharing, and committed effort on sponsored proposals/agreements to ensure reasonableness in relation to the project scope-of-work.

-Review faculty appointments and annual salary.

-Maintain effective internal processes and take corrective action with uncertified effort/delinquent effort statements, and the falsification of information on the effort statement.

-Assist principal investigators with the negotiation of effort levels with sponsors if necessary.

-Maintain effective internal processes to ensure compliance with the applicable and associated policies and procedures.

-Maintain effective internal processes to ensure the accurate and timely processing of labor distribution adjustments and the appropriate allocation of salary costs across various sponsored accounts.

Campus sponsored program offices (e.g., pre-award, account establishment, post award, human resources) depending on the campus specific structure

-Understand and apply the federal government, sponsor-specific, campus, and RF requirements for effort reporting in relation to the sponsored programs lifecycle.

-Provide campus oversight for the operation and maintenance of the effort reporting system.

-Provide campus oversight for the effort statements by assuring their accurate and timely coordination, distribution, and collection.

-Maintain campus effort reporting procedures and provide education/training.

-Respond timely to coordinate/process labor distribution adjustments to ensure appropriate allocations of salary costs throughout the sponsored programs lifecycle.

Definitions

Effort – Is expressed as a percentage of the total amount of time spent on compensated and/or non-compensated work-related activities (e.g., research) in the conduct of a sponsored program.

Effort Reporting – Is the mechanism that is used to confirm that salaries and wages charged to each sponsored program are reasonable in relation to the actual work performed and the activity for which the employee is compensated by the institution. As per Circular A-21, J.10.b.(1)(c) estimates with a degree of tolerance are appropriate.

Effort Statement – Is the documentation used to record and certify an employee’s actual effort on individual sponsored agreements.

Effort Certification – Is the affirmation by the certifier that the reported effort statement percentages are reasonable and accurate in relation to the work performed. Examples of this affirmation include electronic signature, manual signature or e-mail verification.

Extenuating Circumstances – Conditions that may occur that would prevent a certifier from certifying an effort statement in a timely manner, e.g., sabbatical, sick leave, no Internet access, etc.

Federally-Funded – Includes funding for sponsored programs from federal and federal flow-through sources.

Cost Sharing – Is that portion of a sponsored program budget that is contributed by the institution and/or other nonfederal sources – it is not reimbursed by the sponsor. For the purpose of this policy, in accordance with OMB Circular A-110, Cost Sharing also means "matching."

Proxy Certifier – An individual delegated the authority to certify effort for another individual. A proxy certifier has first-hand knowledge of the individual’s effort and suitable means of verifying that the work was performed.

Suitable Means of Verification – Is an indication that the person certifying the effort on behalf of another individual has reasonable knowledge of the work performed by the other individual. Reasonable knowledge can be established by direct knowledge of the certifier, review of payroll records, or the monitoring of sponsored program documentation in support of the work performed.

Other Institutional Activities – Are the activities, other than sponsored programs, for which an employee is paid by SUNY. These activities include, but are not limited to: administrative duties, instruction, and public service.

Related Information

OMB Circular A-21: Cost Principles for Educational Institutions

OMB Memoranda 01-06: Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs, January 05, 2001

Effort Certification Training and Procedures for:

Cost Sharing Policy

Cost Sharing: Guide for Administrators

Records Management Policy

State University of New York: Faculty Salary Recovery from Sponsored Programs (Document Number 1002)

Forms

None

Change History

Date

Summary of Change

September 10, 2014

Revised the When to Certify Effort section and added a definition for Extenuating Circumstances.

June 23, 2014

Changed title back to "Effort Reporting Policy" and major revision of policy.

November 11, 2005

Changed title from "Effort Reporting Policy" to "Certification of Salary Distribution (Effort Reporting) Policy"

October 9, 2001

In first paragraph, change "100 percent of the activity" to "the percent of the activity"

September 19, 2001

New document derived from Personnel Activity Manual (PAR-P-020

 

 

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