Policy statement and procedures
Adopted August 2008
The University will follow the restrictions and requirements of Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions (OMB A-21) and applicable federal regulations with respect to certifying effort charged to federally sponsored projects. The University will maintain an effort reporting system and obtain effort certification from employees in compliance with federal regulation. The University requires employees to certify the accuracy of the percentage of time (i.e., effort) charged to sponsored projects. If effort is not properly certified, salary charges must be removed from the sponsored account.
Reason for Policy
Effort reporting is a federal requirement. The government requires that institutions receiving federal funds for sponsored agreements maintain an effort certification process that complies with the requirements set forth in OMB A-21.
Furthermore, federal and state agencies, private foundations, organizations and industry provide significant funding to enable the University to conduct research, public service and training projects. The University's effort reporting system assures these external sponsors that funds for the projects they sponsor are properly expended by certifying that the salaries and wages charged to the projects are consistent with the effort contributed. All employees involved in certifying effort must understand that severe penalties and funding disallowances could result from inaccurate, incomplete or untimely effort reporting.
Finally, sponsors and auditors must be able to verify that funds allocated for cost sharing have been provided. The effort reporting system is the mechanism the University uses to document cost-shared salary expenses.
The effort certification report accounts for 100 percent of all effort for which the University compensates the individual. Even where the number of hours of effort the individual expends each week substantially differs from the "normal" workweek of 40 hours, effort percentages are based on total effort, not hours.
The University effort certification reports are to be signed by the employee, the principal investigator or other responsible official to confirm that all activities (sponsored and nonsponsored) are reported correctly and that the distribution of effort shown on the certification report reasonably reflects the percentage of total effort that was spent on each activity (OMB A-21, Sec. J-10).
Gallaudet has three reporting periods, which follow the University's academic calendar: fall, spring and summer. Approximately 90 days after the end of each semester, the University will generate effort certification reports, which must be completed and returned within the defined deadline.
Distribution and Certification
Every principal investigator (PI) will receive a packet of reports-one report for each person who is compensated in whole or in part by the PI's sponsored research project. The report will show the employee's projected effort distribution as of the end of that semester. The PI will be responsible for the following:
- Reviewing the preprinted effort report percentages and comparing them to the committed level of effort in the authorized budget.
- Distributing the report and obtaining the employee's certification. Signing the report confirms that effort, as certified, reasonably represents the effort expended during the period. If employee(s) are unavailable to certify their time, then either the PI or another responsible official may sign the report(s), if he/she has suitable knowledge of the employee's effort.
- Retaining a copy of each employee's report.
- Returning the original reports to the Finance Office within the defined deadline.
If the effort reports are not properly certified and returned to the Finance Office in the requested timeframe, the salary charges will be transferred from the sponsored grant account back to each employee's home department.
Actual effort should be closely monitored throughout the life cycle of each award. Significant changes to planned effort distributions should be made as soon as they are known. If, at the end of a certification period, the effort percentage reflected on the certification is not a reasonable estimate of the employee's actual effort, the percentage should be crossed out in ink with the correct percentage written in the margin.
A Personnel Actions (PAF) may be required with a corrected certification report. In accordance with the Cost Transfers Policy, correcting forms should be completed, signed by the appropriate personnel and sent to the Finance Office for processing and approval. The Finance Office will review each cost transfer to ensure the transfers and related explanations meet the budget, allowability and allocability requirements of OMB A-21.
With effort certification, special consideration must be given to the timeliness of payroll cost transfers. University policy requires that the payroll distribution match the effort percentages certified on the effort certification report. Payroll cost transfers, accompanied by appropriate explanations, are strongly encouraged prior to the certification of effort. In the rare instance it is necessary to process a payroll cost transfer to correct a report that has already been certified, the request must include a written justification. The historical salary adjustment should be submitted within 180 days of the period being certified, and it must be approved and signed by the University controller.
Cost sharing describes the portion of a sponsored project's cost that is borne by the University rather than by the external sponsor. One example of cost sharing is where some or all of an individual's effort is expended on a specific sponsored project, as a requirement of the award, but not funded by the external sponsor. Another example would be where a portion of the compensation for an individual's effort exceeds a salary cap imposed by the sponsor, such as the National Institutes of Health. The effort not supported by the sponsor should be reported as cost sharing. It appears on the effort certification report as a department number description beginning with "CS." Any cost-sharing time should be checked for accuracy as part of the review of the overall effort identified in the certification report.
All extensions are tty/voice unless otherwise noted.
- Finance Office (main office, ext. 5299; grants accountant, ext. 5273)
Related Information and Resources
|Terms||Definition and Examples|
|Committed cost sharing||Mandatory or voluntary cost sharing that is pledged in the proposal budget or budget justification, or stated in award documents.|
|Cost sharing||Total project costs not borne by the sponsor; also referred to as "matching" or "in-kind." The University generally refers to cost sharing as labor costs that include salaries, wages, and benefits.|
|Effort||Work or the proportion of time spent on any activity and expressed as a percentage of total time. Total effort for an employee must equal 100%. The appointment serves as the basis for an individual’s total effort. In other words, for a 50% appointment, 100% effort is the 50% appointment. Likewise, for a 75% appointment, 100% effort is the 75% appointment.|
|Historical salary adjustment (HSA)||An adjustment or correction of an internal accounting transaction to transfer salary and fringe charges from past pay periods from one account to another.|
|Mandatory cost sharing||Cost sharing that is sponsor-driven (i.e., required by the sponsor as a condition for proposal submission).|
|Notice of grant award (NOGA)||A document that provides information regarding the award’s important terms and conditions. PIs and departments should refer to it for guidance in managing the project.|
|Overload payments||Compensation to academic personnel (faculty and academic professionals) for work that exceeds the normal scope of their appointments (e.g., extension instruction classes, continuing education).|
|Pre-award costs||Costs incurred prior to the effective date of an award or a budget period.|
|Sponsored projects||An externally funded activity that is governed by specific terms and conditions. Sponsored projects must be separately budgeted and accounted for subject to terms of the sponsoring organization. Sponsored projects may include grants, contracts, and cooperative agreements for research, training and other public service activities.|
|Voluntary cost sharing||Cost sharing that is investigator-driven (i.e., not required by the sponsor as a condition for proposal submission).|
|Principal investigator (PI)||
|Office of Sponsored Programs||
|Vice President of Administration and Finance||
Origination date: August, 2008
Last amended date:
Next review date: August, 2009