Effort Certification The Federal requirement of accounting for your work on their dime!
The legal stuff… (A-21) 2CFR220, J.10.c.(2)(a)-(f) (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. (c) Reports will reasonably reflect the activities for which employees are compensated by the institution. To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, the reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed.
What it really means: • The reporting and confirmation of your time spent conducting any university activity that typically is expressed as a percentage of the total institutional compensated based time (Institutional Based Salary (IBS)) OR • If you work on a sponsored project, you must certify you spent the percentage you said you would.
At this University… We do not have a separate method of accounting for, and certifying effort. We use the Time Sheet for both recording hours worked so we get paid (non-exempts) or exemptions (exempt), and as an effort certification.
Definition Effort: Work or the proportion of time spent on any activity and expressed as a percentage of University time. It does not equate to a 40 hour week, or a fixed number of hours – it’s a “%” of your base salary.
What is the reasonable estimate of effort? • Sponsors recognize that the activities constituting effort are often difficult to separate. Effort certification must often rely on a reasonable estimate of effort, and when estimating, a degree of tolerance (at UA, up to 10% = +/- 5%) is appropriate.
Definition Certify: Assert in writing the correctness of employee % of effort on your paper timesheet or by entering the correct allocation of time in the web time entry site
Why certify? • Well… because the regulations require it, …. • “the reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed.”
What if I don’t?? Severe penalties and funding disallowances could result from inaccurate (False Claims), incomplete, or untimely effort reporting
Who can sign the certification? • An employee, principal investigator or other responsible official with first-hand knowledge of an employee’s effort, or • A responsible official who used a suitable and documented means of verifying the effort (phone call, email from employee, progress report…)
Appropriate Support for Certification • For a faculty member, there may be a variety of sources that report on activity or document the expectations of his or her appointment and may include the following: • Lab notebooks • Progress reports • Email from employee with confirmation of effort expended, sent directly to approver
Certifying the effort • Signer must understand what they are signing • Signer should be very aware of the individual’s work performed and have evidence to-hand • PPAs and fiscal officers should not sign for an employee
Certifying signature • Any employee getting paid from federal funds, or match to federal funds, must review and certify their total effort on all federal projects for each effort reporting period. • Effort promised on your sponsored project must be accounted for and certified to.
OK, so what am I really certifying? • Proposed effort – that which is committed to in the proposal budget. • Committed effort – that which has to be tracked and documented (do not exceed 100% effort on federal programs). • If you got paid 50% of your paycheck from a project during the pay period, then you are certifying to having actually worked 50% of your time on it during that two week period.
My project has cost sharing….?? • Cost sharing is the difference between the effort expended on a project and the effort that is paid for by the sponsor. • Mandatory or voluntary cost share – either still has to be certified to. • Effort committed (expended) but not paid for by the sponsor is cost sharing
Example 1 • PI has agreed to spend • 60% of his time (effort) performing research related activities, • 30% of his time providing instruction through teaching or advisement of students and • 10% of his time providing service to the public or the institution. • The total workload needs to total 100%.
Example 2 • Budget justification may say 30% of the academic year and 1.5 summer months. How much effort is that for this faculty member? • 30% of 9 months is 3 months • 3 months is 24% • 1.5 summer months is 12% • Total effort for this project for one year is 36%
Ok, so when do I certify? • Whether non-exempt or exempt, since certification is tied to the payroll system, you will need to certify bi-weekly. • For now, exempts will continue to use the paper system. • Non-exempts are moving to the Web Time Entry a bit at a time, but it’s still tied to a biweekly certification.
But – I’m not on campus… • If you have internet access, you can still certify biweekly. • If you still use paper timesheets, you can certify when you get back on campus. • If you are really remote, and do not have internet access, you have 30 days from when you get back to fill out paper timesheets to certify your effort. Do not pre-certify!
Summary • The university must have documented effort certification on record for every commitment to a sponsored project. • That effort must have been certified either by the individual expending the effort or a responsible employee closest to the effort • Cannot commit more than 100% on sponsored projects (95% is more realistic)