Effort Certification Amber Roberts Institutional Effort Coordinator Sponsored Projects Administration
The Basics • What? – What is effort certification? • Why? –Why do we certify effort? • When? –When do we certify? • Who? –Who should be certifying? • How? –How is effort certified?
What? • The Effort Certification system: • Documents effort (the amount of personnel activity) expended on federally sponsored projects • Labor Distribution (payroll) information is pulled from Oracle for each employee for creation of the effort statements. Fringe Benefits/OPE and Travel Reimbursements are not included in the calculation. • Certifying is the agreement that an employees payroll distribution and cost share (if applicable) is how they ACTUALLY spent their time on each federal project.
More What? • Certification is the assertion, by an employee or responsible official with suitable means of verification, that labor charges accurately reflect effort (activities) expended over the certification period
The “Statement” • When a person signs they are certifying to this statement: “I certify that I have reasonable means of verifying the activities performed by the above mentioned employee and that the distribution for effort represents a reasonable estimate of the actual work performed by the employee during the period covered by this report.” • What is considered reasonable? • Within 5% per line
Why? • OHSU’s Effort Certification system was developed in direct response to the Federal Office of Management and Budget (OMB) Circular A-21 • A-21 addresses “principles for determining costs applicable to grants, contracts, and other agreements with educational institutions”
More Why? • A-21 aims to ensure that the Federal Government bears its fair share of total costs • A 21 states : • Institutions must be able to document the distribution of payroll charges using an acceptable method. OHSU uses after the fact Activity Records (J.10.c(2) in A21) • Failure to comply with A-21 can have very serious consequences
Even More Why- Committed Effort • What is the Committed Effort? • It’s the effort commitment made at the time of award for the Principal Investigator and Key Personnel. • Why is this important? • We must honor our effort commitments. Most federal sponsors consider a 25% or greater reduction an issue. • Auditors will compare committed effort in a grant application to actual effort on the certified Effort Certification Statements.
Even More Why- Committed Effort • OHSU follows NIH guidelines • http://grants.nih.gov/grants/policy/nihgps_2001/part_iia_5.htm • Grantee must notify sponsor if PI or other Key personnel reduce their committed effort by 25% or more • A letter must be generated by Principal Investigator detailing the new effort commitment requested. This is co-signed by the SPA Director. • Grantee can always increase effort above proposed
Faculty Committed Effort • Faculty cannot have 100% Effort on Sponsored Funding with the exception: • If PI is receiving 100% salary support on sponsored projects they need a signed statement on file from their departments Dean or Director specifying that they are 100% committed to research. This means the PI is does not have administrative, teaching, or clinical responsibilities and is solely working on their research projects.
When? • OHSU certifies effort semi-annually • Effort periods end Jun 30 & Dec 31 • Effort periods close in February and August • Effort Process Timeline http://www.ohsu.edu/research/rda/spa/docs/effcerttl0110_0610.pdf
IEC Reminders • Institutional Effort Coordinator sends email reminders: • That the effort period has ended (December 31st and June 30th) • Upcoming close and LD Lockout (In February and August) of the effort period • Statements are ‘in the mail’ and to check for packets • Upcoming deadline for turning in statements (April and October)
Who? • An employee is required to complete an Effort Certification Statement (ECS) if… • Their activities are partially or totally devoted to a sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity) • AND, pay is partially or totally paid from such an agreement, OR represents cost sharing
Who else? • Graduate Research Assistants receiving GRA support payments (object code 5198) need to certify their effort. • HR has determined GRA’s to be “quasi” employees. • Research Training Fellows receiving stipend payments do not certify effort. They are not considered employees and are here strictly for a training experience.
Cost Sharing • Cost sharing is defined as the portion of the project or program costs not borne by the sponsor. • The majority of Cost Sharing commitments are met through effort/payroll expense • Cost Shared Effort must be included on Effort Certification Statements and certified. • Cost Sharing must be from a non-federal account—most likely a General Ledger Account.
How? • Oracle identifies individuals who are receiving effort related salary from federally sponsored and cost sharing accounts in the Payroll Module. • Note: If you have someone who is receiving all of their salary off of the GL, but have activities benefiting a project as cost sharing please be sure to contact the IEC at the close of the effort period. • Statements are generated showing the effort related percentages of payroll distribution the individual received on each account.
What if cost sharing or corrections are needed? Examples can also be found online at http://www.ohsu.edu/research/rda/spa/effortworkshop.shtml
Cost Sharing • If applicable, cost shared effort needs to be shown on a ECS. • If a cost share companion account has been set up, the account should be shown already on the statement. • If a companion account is not being used, cost sharing must be shown using a hand correction showing support from a non-federal sponsored account to the sponsored account.
Salary Cap? • NIH prohibits employees from receiving a salary greater than the established cap ($199,700 for calendar year 2010) http://grants.nih.gov/grants/policy/salcap_summary.htm • Any amount above this cap must be considered Cost Sharing and charged to the appropriate non-federal account • For more information about the salary cap, please register for the Advanced Effort- Salary Cap PEP class
Change to the % of Payroll Distribution • The ECS is generated but the % of payroll needs to be changed. 1) Enter a change in Labor Distribution in Oracle to reflect the correct % of payroll 2) Do a hand correction to amend the ECS to mirror the Labor Distribution Change. Changes should be made to the left of the % payroll column 3) Complete a Labor Cost Transfer Form (LCTA Form) http://www.ohsu.edu/research/rda/spa/docs/lcta.pdf 4)Submit all paperwork together to SPA
Suspense Activity Clearing • Suspense is where Labor Distributions go when there is not an account to place it in! • It starts with a 0051 Fund Number • All Suspense must be cleared on ECS and in LD before a statement can be accepted.
Suspense Corrections • The same protocol exists for the % of payroll change 1) Enter a change in Labor Distribution in Oracle to reflect the correct % of payroll 2) Do a hand correction to amend the ECS to mirror the Labor Distribution Change. Changes should be made to the left of the % payroll column 3) Complete a Labor Cost Transfer Form (LCTA Form) http://www.ohsu.edu/research/rda/spa/docs/lcta.pdf 4)Submit all paperwork together to SPA
TBD Correction • The ECS is generated but an award is missing because an account is not yet set up in OGA. 1) Write in TBA for Grant Account Number 2)Show Effort in the Cost Sharing Column 3) Once OGA account is set up, LD can be changed and a LCTA form will be needed but you will not need to do an amended ECS.
Additional Info & Things to Remember • Please document effort for each line in the far right column—this helps to explicitly show what the person’s effort is for each account • Effort must add up to 100% • The date the statement was signed must be included • If a responsible official signs (this must be someone who has substantial knowledge of the individual’s effort), they must also include their printed name and check one of the relationship box options
Additional Info & Things to Remember • Use pen (not pencil) to make corrections • DO NOT use White out • Total effort column needs to sum to 100%. Cost sharing columns need to sum to zero • SPA cannot amend these forms on your behalf.
Additional Info & Things to Remember • A great tools to use before and after you get statements: • Effort Certification Process Timeline (http://www.ohsu.edu/research/rda/spa/docs/effcerttl0110_0610.pdf) • Effort Procedure (http://www.ohsu.edu/research/rda/spa/docs/effortcertproc.pdf) • OGADW Employee Effort Report Distribution by Period in Discoverer • If you aren’t sure about something, call the Institutional Effort Coordinator!
Additional Info & Things to Remember • There is approximately 30 days between the end and the close of the effort period. This time allows you to review and make any needed LD Changes. This helps reduce the need for payroll related hand corrections on the ECS. • DECs have approximately 35 business days between the time statements are distributed to the return deadline. • Outstanding statements are subject to the Notification Process • If DECs have a statement that will be late, please send in what has been certified before the deadline.
Signature Reminder • It is generally inappropriate for a Departmental Effort Coordinator or a Department Chair to sign all of the Effort Certification Statements in the unit or department.
Let’s Review! • What Tools Are Available to with Effort Certification? • Effort Timeline • Effort Procedure • OGADW Employee Effort Report Distribution by Period • Institutional Effort Coordinator (IEC)
Let’s Review! • Who needs an Effort Certification Statement? • Anyone who’s effort/activity is partially or totally devoted to a sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity) • AND, pay is partially or totally paid from such an agreement, OR represents cost sharing
Let’s Review! • When does OHSU Certify Effort? • Twice Each Year (Jan1-June 30 & July 1-Dec 31) • How much time is provided to change Labor Distribution after the Effort Certification Period Ends (either June 30 or Dec 31)? • 30 business days • Note: Keep an eye on the Effort Certification Process Timeline for deadline dates and when LCTA forms must be in for adjustments that do not auto approve.
Let’s Review! • How many days after SPA distribution date are the ECS form due back to SPA? • 35 business days • The deadline date is listed on the Effort Certification Process Timeline • How many notifications are sent for late Effort Certification Statements? • 5, the last to the Dean or Director of the Department
Let’s Review! • What is a reasonable estimate? • +/- 5% per line • True or False? DECs must wait to submit all their ECS to SPA until they have all been signed! • False!!! Please submit all certified statements before the effort deadline
Let’s Review! • True or False? As a the Department Effort Coordinator, I truly do know what folks are up to in my department, and thus I can sign the ECS form. • Most likely FALSE!!! Remember what the “statement” says and what certifying means.
Let’s Review! • True or False? I can edit the Effort Statements with Pencil • FALSE. Pen please! • True or False? I can white out on Effort Statements. • FALSE. The use of white out voids the effort statement and a new one will be needed.
Let’s Review! • If you receive an ECS that needs a correction, what steps do you need to take? • If payroll related, correct LD to match actual effort performed (if cost sharing-no LD may be needed) • Hand Correct Statement (using PEN) to reflect Effort change and obtain appropriate signatures • Complete LCTA Form if LD change was made • Submit all to SPA
One last thing! • What if you need to correct an already certified statement? • Amending a statement erodes the credibility of the certifier and the statement so please TRY TO ALWAYS AVOID THIS! BUT IF YOU MUST….There is a process for amending and recertifying effort statements. • Submit an LD adjustment, LCTA form and an amended ECS with hand corrections • Complete a Effort Recertification Form located on SPA’s website under Effort http://www.ohsu.edu/research/rda/forms.shtml#fm
Don’t forget the Effort Procedure is available online • The full text of OHSU’s Effort Certification Procedure is available on the SPA website: http://www.ohsu.edu/research/rda/spa/docs/effortcertproc.pdf
Questions? If you think of something later you can contact the IEC at firstname.lastname@example.org or at ext. 4-6984.