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 in compliance with federal regulations.
Certification is completed by using the Effort Certification Reporting Tool
(ECRT) or the approved manual effort certification statement template. The certified
statement will reasonably reflect all of the employee's professional effort
during the reporting period. All faculty and non-faculty principal investigators
(PIs) must certify their own effort. 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) can certify the effort using suitable
means of verification that the work was performed.
For faculty and non-faculty PIs:
- The effort statement must accurately reflect the time PIs spent preparing
proposals and conducting other administrative work. Therefore they cannot
certify 100% effort on sponsored projects unless they are on sabbatical from
their teaching and other duties.
- PIs cannot certify 0% effort on a sponsored project for the entire grant
period. They must certify at least 1% effort on an effort statement during
any one of the effort periods to accurately reflect their leadership of the
project. This 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 notify Sponsored Projects Administration to determine
whether prior sponsor approval is required.
PIs have the responsibility to ensure that the effort of individuals working
on their sponsored projects are 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. (Federal auditors argue that if a fraction of
a person's effort is unknown, then it is impossible to determine the entirety
of that effort). 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).
Effort reporting is a federal requirement. As a condition to receive federal
funding, institutions must maintain an accurate system for reporting the percentage
of time (i.e., effort) that employees devote to federally sponsored projects
(see OMB Circular A-21, Cost Principles for Educational Institutions - Compensation
for Personal Services). The University has chosen to apply this standard to
all sponsors.
The University's effort reporting system assures these 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 funds allocated
for cost sharing have been provided. The effort reporting system is the mechanism
the University uses to document cost-shared salary expenses.
Effort Unit web page for
forms, templates, and instructions.
- Committed Cost Sharing
- Mandatory or voluntary cost sharing that is pledged in the proposal budget,
budget justification, or stated in award documents.
- Uncommitted Cost Sharing
- Voluntary cost sharing funds not pledged in the proposal and subsequently
not stated on award documents. This type of cost sharing is above that agreed
to as part of the award. This is commonly referred to as voluntary uncommitted
cost sharing and for faculty and senior researchers, does not have to be documented
or reported.
- Mandatory Cost Sharing
- Sponsor-driven, i.e., cost sharing that is required by the sponsor as a
condition for proposal submission.
- Voluntary Cost Sharing
- Investigator-driven, i.e., cost sharing funds are not required by
the sponsor as a condition for proposal submission.
- Cost Sharing
- The terms "cost sharing," "matching," and "in-kind" refer to that portion
of the total project costs not borne by the sponsor. The University generally
refers to cost sharing as labor costs.
- Effort:
- Effort is generally defined as 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% (+ or - 1% 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):
- The Historical Salary Adjustment (HSA) is an adjusting or correcting internal
accounting transaction to transfer salary and fringe charges from past pay
periods from one account 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
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:
- Compensation to academic personnel (Faculty and Professional Academic) for
work that exceeds the normal scope of their appointments, e.g., extension
instruction classes, continuing education.
- Preaward Costs:
- Costs incurred prior to the effective date of an award or a budget period.
- Retroactive Pay:
- Pay received for work performed in prior pay periods.
- Senior Researcher:
- A non-faculty principal investigator. This is a term used by the federal
government.
- Sponsored Projects:
- 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, 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.
- Researcher Employees
- 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:
- Ensure process is managed so that all parties have adequate time to complete
certification and effort statements are completed within given timeframe.
Facilitate the department effort certification process. Notify SPA Effort
Unit when cost sharing changes on those grants where SPA entered original
cost sharing. For other cost sharing arrangements, adjust cost sharing using
the ECRT system. Submit accurate and timely effort statements. Attend required
formal training.
- 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.
- Grant Administrators, Sponsored Projects Administration:
- During award setup, confirm that committed cost sharing is documented on
the NOGA and that cost sharing account is established when cost sharing is
required 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.
- Amended:
- June 2008 - Made changes to reflect EFS implementation.
- Amended:
- February 2004 - Revised policy and procedures to reflect use of new Effort
Certification and Reporting Tool (ECRT).
- Amended:
- October 2003 - Added link to 9 Over 12 Payroll Adjustment Worksheet. Added
clarification for certifying effort and charging travel costs.
- Amended:
- 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.
- Amended:
- 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.
- Amended:
- December 2000 - Updated to reflect the use of the "Historical Salary Adjustment"
rather than the discontinued "Type 38 Payroll Journal Voucher".
- Amended:
- September 2000 - Deleted reference to obsolete Sponsored Projected Employee
Verification Statement. Clarified who is authorized to make changes to the
statement.
- Amended:
- 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.
- Amended:
- 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.
- Amended:
- May 1996.
- Effective:
- September 1995
- Supercedes:
- Effort Reporting Policies and Procedures - Executive Summary.
-
To obtain a copy of a historical policy,
e-mail the U Policy Librarian at policy@umn.edu or call 612-624-4372.
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