|
1. What is effort and effort reporting?
Effort is the proportion of personnel time spent on any institutional activity expressed as a percentage of the total institutional activities of the employee. Effort reporting is a process required by the federal government to verify that salary and wages charged to sponsored projects are reasonable and reflect actual work performed. Effort reporting provides a means of verifying that:
- Effort compensated by a sponsored project has been performed as promised (direct charge), and
- Effort expended on a sponsored project, but not compensated by that project (cost sharing), has been performed as promised.
Effort reports must account for all effort for which the University compensates an individual. This includes all effort expended on sponsored projects, administration, business development, instruction and nonsponsored scholarly activity, clinical activity, and other activity as prescribed in OMB Circular A-21. It does not include effort for which the employee receives compensation directly from another entity (e.g., outside consulting work) or incidental work for which supplemental compensation (i.e., extra state/overload compensation) is paid. It is important to consider that effort is not calculated on a 40-hour workweek or other University approved standard workweek. Thus, even when the number of hours of effort the employee expends during the period
reported substantially exceeds the “normal” workweek of 35-40 hours, the total effort expended by the employee must account for all the work performed by the employee and cannot exceed 100%.
Example – If the employee worked 40 hours in one week on a sponsored project and 20 hours in the same week on an unrelated University project, then the employee’s effort report should show 67% effort devoted to the sponsored project (40 hours divided by 60 total-effort hours) and 33% on the unrelated University project -- regardless of the fact that the employee’s normal work week might be 40 hours. Effort is expressed as a percentage based on the total number of hours worked by the individual and is not reflected as hours. The total effort expended cannot be more than – or less than – 100%, unless the employee is part-time in which case the total effort must be consistent with part-time status.
2. Why is effort reporting important?
Certified effort reports provide auditable documentation to confirm that FIU personnel did, in fact, commit the level of effort outlined in the proposal. Both direct and indirect costs may be disallowed and penalties imposed if the Federal government finds such documentation to be inadequate. In addition, criminal charges may be brought against an individual who falsely certifies his or her effort.
3. Who is subject to effort certification requirements?
Any individual, who works any portion of his or her time on sponsored projects or activities whether compensated or uncompensated by that project, is required to certify effort using the web-based Time & Effort Certification System (TECS).
Faculty, A&P, USPS exempt, graduate students paid bi-weekly via OPS contract and other OPS contract employees will certify their effort on sponsored activities 3 times per year (Fall, Spring, Summer).
USPS and OPS personnel paid via timecard will continue to provide the required certification of their effort through completion and signature of new timecards, which require supervisor signature and approval. Signed timecards provide auditable documentation of an employee’s certified effort.
4. Is it necessary to certify effort associated with overload/extra state compensation?
No. When an employee receives compensation directly from another entity (e.g., outside consulting work) or incidental work for which supplemental compensation (i.e., extra state/overload compensation) is paid, this effort need not be considered.
5. Who should certify effort reports?
Federal effort reporting guidelines require that either the individual or someone having firsthand knowledge of the activities performed by the employee must certify effort reports. OMB Circular A-21 provides that the person signing the effort report must have "suitable means of verification that the work was performed." In most cases, this will be the employee performing the work. In the employee’s absence, the Principal Investigator for a specific project or a supervisor designated by the PI may also certify the effort of the employees working on the PI’s project. The PI must be able to verify that persons paid on their sponsored projects actually performed the work and must be in a position to provide verification of the effort certified.
Certification of effort by a departmental secretary or other staff is not permitted.
6. How often do I need to certify effort?
Effort certification is required at the end of each semester (3 times per year) for that semester’s activities. Employees are responsible for completing effort certification reports within 2 weeks from the time they are distributed.
7. When is it necessary to make adjustments to effort or payroll distribution?
Anytime that payroll does not accurately reflect how the employee spent his/her time on the certified effort report by a margin of +/- 5%, an adjustment to effort and payroll distribution is necessary. OMB Circular A-21 and FIU policy recognize that activities that comprise an individual’s total effort (teaching, research, service, administration, etc) are often difficult to separate and that “an exact assessment of factors that contribute to costs is not always feasible, nor is it expected.” Certification must rely on a reasonable estimate of effort during a specified time period, and when estimating, a degree of tolerance is acceptable and appropriate.
FIU recognizes this degree of tolerance to be no more than +/- 5%.
8. What is the minimum effort required on a sponsored project?
FIU requires at least 1% FTE commitment (or the minimum required by the program if greater than 1%) on the part of the Principal Investigator and other key personnel during the period of the project. Investigators and other key personnel must meet the proposal/award effort obligations for each sponsored project or arrange with the PI and OSRA to adjust their committed effort with the sponsoring agency if necessary. This minimum requirement does not apply to equipment grants, dissertation support, training grants or other awards intended as student augmentation, or limited-purpose grants such as travel grants or conference support. In instances where the committed effort is expended but not charged to the project, the effort must still be certified to fulfill the required or committed cost sharing.
9. How do I determine if my effort is a direct charge or cost sharing?
Cost sharing is a commitment of institutional funding or resources to support a specific sponsored project for which the University is not compensated by the sponsoring agency. There are three types of cost sharing:
- Mandatory/Committed: cost sharing that is documented in the proposal and agreed to in the sponsor’s awarding documents.
- Voluntary/Committed: cost sharing that the sponsor did not require, but the proposal nonetheless included, and subsequently became a condition of the award.
- Voluntary/Uncommitted: cost sharing that the University provided to the project, but was not required by the sponsor. This type of cost sharing occurs when effort exceeds pay.
Only mandatory/committed and voluntary/committed cost sharing must be tracked and reported to the sponsoring agency. Voluntary/uncommitted cost sharing need not be reported to the sponsoring agency; however, all effort (whether cost shared or direct charged) must be tracked and reported even if the effort is voluntary/uncommitted cost sharing. It is important to note here that according to University policy, only mandatory cost sharing shall be permitted on proposals to sponsoring agencies.
10. My sponsoring agency requires that I express my effort in terms of person-months, but I must certify my effort in terms of % effort. How do I convert person-months to % effort?
To convert person-months to % effort, divide the number of person-months by the total number of months by the total number of months in the period (4.5 months = Fall, 4.5 months = Spring, 9 months = Academic Year)
Example:
1.5 person-months in the summer:
1.5 (person-months)/3 (total number of summer months) = 50% effort
3.5 person-months in the academic year:
3.5 (person-months)/9 (total number of months in the academic year) = 38% effort
11. If a 9-month employee is awarded salary for 100% of their effort during the Summer term, can they still participate in non-grant related activities? Take a vacation?
No. If an employee has been awarded 3-months (i.e., 100%) of their summer salary by an extramural agency, the agency expects that individual to devote 100% of their effort on the funded project(s). This means that normal academic year activities should be minimized during the summer months (e.g., teaching, advising, committee service, etc.). This also means that vacation time off is not allowed during the summer months.
12. If I am the PI on a grant that pays 100% of my summer effort, can I direct students working on my research?
Yes. Effort associated with directing the research of students working on the PI’s research is allowable effort.
13. How does a No Cost Extension affect my effort commitment?
During a No Cost Extension, the effort commitment is the same as in preceding years. A PI can reduce their effort by up to 25%, but this must be communicated and agreed to by the sponsoring agency. Without this agreement, the PI will be responsible for completing the original effort commitment.
14. What should I do when my awarded budget is less than the proposed budget?
When the awarded budget is less than the proposed budget, a reduction in effort commitment might be necessary. If the awarded budget is reduced by 25% or more, an appropriate effort reduction can be requested from the agency.
15. What should I do with my certified effort report?
When you have completed your effort certification, print and sign the report. If you are not the PI on the project(s) then send a copy of the signed report to the project’s PI. The PI must keep a copy of all effort reports of individuals paid from their grants.
|