The federal government, through the Office of Management and Budget (OMB) Circular A-21, paragraph J.10, requires effort certification on federally-sponsored activity. In order to receive and maintain eligibility for funding, sponsoring agencies require accurate and reasonable documentation to support that labor charged to sponsored activities are consistent with the effort expended. This certification is reviewed for two purposes:
1. Verify that the percentage of effort placed on a federal award is not less than the percentage of salary charged to the grant, and that the effort commitment to the grant has been met.
2. Capture any voluntary cost sharing by indicating an excess percentage of effort as compared to the percentage of salary.
This Effort Certification Policy is intended to meet this federal requirement.
A. After-the-Fact Reporting
Truman State University uses an “After-the-Fact Activity” system to comply with the federal effort certification requirement. Under an after-the-fact system, distribution of salaries and wages for faculty/staff working on externally-funded projects will be supported by Faculty/Staff Effort Certification Reports. Charges are made initially on the basis of estimates made before the services are performed. Faculty/Staff Effort Certification Reports will reflect an after-the-fact reporting of the actual percentage distribution of activity of employees. If significant (>10%) differences exist between the charges and actual distribution, the charges to the grant will be adjusted to reflect actual activity.
The Grants Accounting Office will be responsible for sending out the activity reports to those paid compensation from federally funded grants. Employees paid by the grant will be responsible for timely completion and submission of the certification reports. The Principal Investigator will be responsible for timely approval and submission of certification reports from employees funded through his or her grant. The appropriate Dean will be responsible for reviewing and approving effort reports for grants under their areas. The Executive Vice President for Academic Affairs will be responsible for determining the up-front estimates of effort prior to the payment of salaries, and for the funds needed to reimburse the grant should the actual effort reported for the federal funds be greater than 10% under the amount indicated by grant terms. The Executive Vice President for Academic Affairs will also review and approve effort reports where a second approval is needed. The Grants Accountant will be responsible for comparing completed effort reports with the terms of the grant and forwarding any concerns to the Comptroller.
Faculty/Staff Effort Certification Reports will reasonably reflect the percentage distribution of efforts expended by Truman State University faculty and exempt (salaried) professional staff involved in federally-funded grants, contracts, and cooperative agreements. The report will account for 100% of an employee’s actual effort for the given time period.
100% effort is defined as the effort expended to accomplish the full set of activities encompassed by Truman State University appointments regardless of the actual number of hours expended on those activities. 100% effort is not defined as a number of hours or days per week on an activity because it will likely be different for each faculty/staff member and may vary during the year. The number of hours implicit in an individual member’s 100% must be reasonable and supportable to external reviewers if requested.
The employee should indicate the percent effort (time worked on an individual activity divided by the total time worked for Truman State University) for all federally-sponsored research and university activities.
The employee should provide an accounting of all effort expended on a sponsored activity, even if the sponsor did not compensate the employee for that activity, which constitutes “cost sharing.” This can occur on a mandatory or voluntary basis. Mandatory cost sharing occurs when it is required by the sponsor at the time of application. Voluntary cost sharing represents additional effort expended on a project that is not required by the sponsor. The Principal Investigator should record all effort expended on sponsored projects regardless the source of compensation.
Effort Certification Reports are intended for employees who do not complete time sheets for payroll purposes. Therefore, clerical staff and student workers do not need to complete the Faculty/Staff Effort Certification Reports as long as they complete time sheets and submit those to the Payroll Section of the Business Office prior to payment.
Principal Investigators should verify the accuracy of information provided by employees working on their grants.
Faculty/Staff Effort Certification Reports are required for three reporting periods annually. Effort certification report requests will be distributed to all applicable employees approximately 15 days from the close of a reporting period. Completed reports must be submitted to the Grants Accountant, McClain Hall 106, no later than the 30 days after the distribution of the effort certification report request. The reporting periods and approximate submittal deadlines are provided as follows:
a. Summer (June 1–August 31); submittal deadline – October 15
b. Fall (September 1 – December 31); submittal deadline – February 15
c. Spring (January 1 – May 31); submittal deadline – July 15
Completed Faculty/Staff Effort Certification Reports will be filed in the Grant Accountant’s Office.
C. Other Items of Note
1. When a Principal Investigator is absent in excess of 90 days from his/her project, approval must be obtained from the sponsoring agency.
2. Time spent in the preparation of proposals cannot be charged to a sponsored grant. Therefore, it is inappropriate for an employee to be paid from sponsored funds to prepare and submit proposals.
D. Review of Policy
This policy will be reviewed at the end of the 2009 fall semester with input from those using the form.
For further information, contact the Grants Accountant at 785-4664.