Effort Reporting and Certification

Basics of Effort Reporting and Certification

This module reviews the importance of effort reporting and the process of effort certification at PSU. It is required training for all PSU personnel with any salary paid from sponsored programs. Graduate students, adjunct operating staff, and others who support sponsored projects are encouraged, but not required, to complete this training.

PSU’s Office of Sponsored Programs (OSP) developed this training and is responsible for ensuring compliance with policies and regulations from external sponsors.

Please review these materials carefully. The Internal Review Approval Form used for pre-award proposal approvals will require you to certify that you have reviewed and understand your effort reporting and certification requirements for sponsored programs.

Outcomes

Gain a working knowledge of:

  • Basics of Effort Reporting and Certification
  • PSU’s Certification Process
  • Managing Effort on Sponsored Projects
  • Areas of Caution

Basics of Effort Reporting and Certification

Effort – the time (expressed as a percentage) you spend on any project whether the sponsor pays your salary or not

Effort Commitment – total projected amount of time expected to be spent on a sponsored project or other USNH activity

Total University Effort – all activities for which you are compensated from university administered funds for effort on performing regular duties and effort paid as additional pay (additional pay not based on effort is excluded, ex. transportation allowances)

Institutional Base Salary – your regular pay for performing regular duties (excludes pay earned outside of regular duties whether internal or external to the university)

Regular Duties – duties and responsibilities associated with your occupational type and/or classification, as described in the initial appointment letter, subsequent communications, and/or work plan and position description

Effort is…

Effort Certification is a means of assuring sponsors that your level of effort, expressed as a percentage of total university effort, corresponds to the amount you were paid from the project. This assurance process is required by PSU policies and federal regulations.

This is accomplished through your effort report and certification. The effort report includes all funds from which you were paid for total university effort. The statement will include cost-shared effort as well. All hourly employees certify via the bi-weekly timesheet and do not receive an annual effort report.

University policies and federal regulations require PSU to maintain systems and procedures documenting the distribution of activity, and associated payroll charges, to each sponsored award.

Effort is not…

Effort is not based on a 40-hour work week

This concept generates frequent questions and discussion. Your total university effort is all your activities related to your regular duties, defined in the appointment documents, plus additional pay based on effort that is not incidental. Total university effort is always 100% regardless of the number of hours you work, or whether your total effort is determined to be a full time or less than a full time position.

Example 1 – Your position, and total effort for the university, is defined as a 75% full time equivalent position. You work at least 30 hours per week and some weeks more than 40 hours including time at night and on weekends. Your total university effort is 100%.

Example 2 – Your position is full time however you normally work 80 hours per week. Your total university effort is 100%.

Level of Precision

Federal rules do not define the level of precision in effort certification. An acceptable practice, and one used at PSU, is to require a change in the effort report and the labor cost distributions, when actual effort on sponsored programs varies by 5% or more from the reported effort. Differences of less than 5% do not require labor cost re-distributions unless the associated costs are unallowable such as for effort on preparing competitive proposals.

Federal rules applicable to federal grants state that effort reports should “reasonably reflect the activities for which the employee was compensated by the institution.”

“… it is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate.”

In a few instances, sponsors have asked faculty to keep detailed and precise time sheets to support the level of effort on specific program activities. This practice is unrelated to effort reporting.

De Minimus Effort

Some activities are so infrequent and so brief that they cannot and should not be separately accounted for in the effort report but instead should be equitably allocated to sponsored and non-sponsored activities. When reviewing your effort report you can ignore activities that are less than 1% of your total university effort.

Examples of activities that you can consider to be de minimis effort include participation in departmental meetings, annual staff performance reviews, and enrolling in employee benefit plans.

Writing competitive proposals and regular administrative responsibilities, e.g. serving as a department chair, cannot be considered de minimis.

Faculty Compensation

Faculty Compensation – Summer Salary

Faculty with academic year appointments are permitted (under university policies) to accept summer appointments for up to two and a half months of full effort. University related activities (teaching, administrative, and grant writing) may reduce the amount of effort that may be charged to sponsored programs in the summer. A request for summer salary indicates a commitment to put forth the comparable effort on the particular project during the summer period. Effort expended during the academic year does not satisfy a commitment related to receipt of summer salary. While personal time off may be taken during the summer period, it is not appropriate to consider time off during a period for which the faculty member is receiving summer salary.

Proposed Contribution of Effort

In preparing proposals, PIs/PDs must propose some level of activity (1% or the minimum required by the program) unless specifically exempted by the sponsor. PIs/PDs are expected by PSU to provide reasonable estimates of the percentage of effort for themselves and all other key personnel necessary to carry out the proposed project.

PSU typically does not cost share/contribute effort on a voluntary basis. Approval for Voluntary Committed Cost Sharing of Effort must be obtained prior to proposal submission from the PSU Office of Sponsored Programs, through the internal review approval process. This type of cost sharing is agreed to as part of the award and is required to be documented, tracked, and reported. Voluntary Uncommitted Cost Sharing of Effort is not included in the effort report.

Maximum Allowed Regular Pay

Pay for administrative, instruction, service, clinical activity, institutional governance, and new or competitive proposal preparation must not be charged directly to externally-Sponsored Programs unless the activities are specifically approved activities of those Sponsored Programs. With the proviso that unrelated and unallowable activities may not be charged, a maximum of 95% of a PSU employee’s Regular Pay during each fiscal year may be charged to Sponsored Programs. With written approval from the Provost, exceptions can be made up to 100% if the employee is working exclusively on Sponsored Program(s).

Proposal Commitments and Overcommitments

It is a common and acceptable practice for combined faculty effort in active and proposed awards to exceed 100% of full time effort with the expectation that not all proposals will be funded. If new funding results in total funded effort commitments that exceed 100%, an adjustment is necessary. In some situations, prior sponsor approval is required.

Prior approval is required from federal sponsors for (1) a change in key personnel or (2) PI/PD absence for more than three months or a 25% reduction in committed effort.

Total University Effort (TUE)

Total University Effort (TUE) is all activities for which you are compensated with USNH-administered funds for performing regular duties and for work effort for which you receive additional pay. Types of additional pay unrelated to effort (e.g., Employee Transition Allowance or monetary awards for recognition) are excluded from consideration for TUE. TUE is 100% regardless of FTE %.

TUE includes all USNH effort-based activities regardless of when during the daytime, evening, weekend, or year, or where (e.g., on campus, at home, while traveling) the activities take place. TUE is not based on a 40-hour work week, but rather on the total USNH hours the employee spends on the combination of Regular Duties and Effort expended for Additional Pay. For example, if a person averages 60 hours per week on USNH activities and spends an average of 15 of the 60 hours per week on a Sponsored Program, that person is spending 25% effort on the Sponsored Program and 75% on other duties.

Not Included in Total University Effort

The following activities are not part of your total university effort and therefore should not be included in your effort report:

  • External consulting when you are not compensated by USNH
  • Clinical activity in a facility unaffiliated with USNH with no USNH compensation
  • Professional society participation unless USNH reimburses travel and other related costs
  • Journal peer review
  • Funding agency proposal review unless USNH reimburses travel and other related costs
  • Volunteer or community activities or public service not related to USNH

Allowable Activities

A sponsored project can only be charged for activities that directly relate to the work on the project. An allowable activity should be solely to advance the work on the particular sponsored project during the performance period.

Specific activities that are allowable include:

  • Directing or participating in any aspect of the research
  • Writing a progress report for the project, sometimes called a continuation proposal
  • Holding a meeting with lab staff to discuss the research project

Activities contributing to, and intimately related to, the research such as participating in related seminars, delivering special lectures about aspects of the research, presenting research from the project at a professional conference, reading scientific journals to keep up to date, and mentoring graduate students on the research project.

Unallowable Activities

Activities that cannot be charged to a sponsored project include:

  • Proposal-writing, except for progress reports, including developing the necessary data for the proposal, writing, editing, and submitting the proposal
  • Administration such as serving as a departmental chair
  • Serving on a PSU committee, such as strategic planning, IRB, or faculty tenure
  • Instruction including office hours, counseling and mentoring when not related to the research project
  • Fundraising

Effort Certification Process and Procedure

Plymouth State University requires effort certification twice per year: one certification for the Academic Year (AY), and another for summer.

We do this with your assistance in completing the effort report and certification. A Personnel Activity Report (PAR) serves as the effort report and includes all accounts from which you were paid. The statement will include cost-shared effort as well. Non-status hourly employees certify via the bi-weekly timesheet and do not receive a PAR. Your Personnel Activity Report (PAR) is generated from payroll files by the Office of Sponsored Programs. The PAR contains a list of the projects and PSU activity that are paying your salary along with the percentage of effort committed to those projects.

To certify your PAR:

Using suitable means of verification, review the report and verify that the work associated with the effort was performed.

If actual effort accurately reflects what was committed, please sign the PAR and return it to the Office of Sponsored Programs, MSC 17.

If actual effort is different from committed effort, note the difference in the space provided on the right side of the PAR and return the report to OSP. Differences of 5% or more require us to change how your salary was charged. For example, the employee committed 50% of his or her effort to a project but ended up expending 60%. This is a change of 10% (greater than 5%). Note this change on the right side of the PAR so OSP can make the appropriate changes. This is an unusual circumstance.

How percentages on the PAR are calculated

The computed percentages column on the PAR is based on actual salary cost distributions. Salary costs are distributed based on the initial planned labor distribution established by the PI/PD and entered by OSP at the beginning of the year. The initial planned labor distribution will be modified by the PI/PD during the year when there is a significant change in work activity directly or indirectly charged to sponsored agreements.

How revisions to effort allocations are processed

When actual effort allocations vary by 5% or more from computed effort allocations you should enter the revised % on the PAR before signing it. OSP will reallocate the labor costs based on your revised effort certification. Revisions should be entered as soon as possible to correct reports and billing to sponsors in a timely manner.