The Basics of Effort Reporting

Introduction

This training document was largely developed as a course by the office of Research and Sponsored Programs (RSP) University of Wisconsin – Madison and has been modified for use by the University of Massachusetts. The University of Massachusetts gratefully acknowledges and appreciates the use of this material for our time and effort training.

This course is for faculty and academic staff who work on sponsored projects, and for others who serve as principal investigators on sponsored projects. Administrators and other members of the campus research community may also find it useful.

Course goals

The goals of this course are:

• To explain the key principles of effort on sponsored project
• To communicate the requirements that apply in proposing, managing, and certifying effort on sponsored projects
• To provide training in how to certify effort with the Employee Compensation Compliance (ECC) system

Why is it important to know this?

Each year, the university receives millions of dollars from organizations, including the federal government, that sponsor research and other UMASS activities. As the stewards of those funds, it is our obligation to comply with federal and university requirements to certify faculty and staff effort on sponsored projects.
To certify effort accurately, we must understand some key principles that are stipulated by the federal government. Many universities have paid multi-million dollar fines for not certifying in accordance with these principles
Currently, effort certification is a hot topic among federal auditors. A failure to propose, manage, and certify effort correctly could jeopardize the university's federal funding and lead to penalties for the university.

Coming attractions

Here are some of the key points you'll encounter in this course:

• Effort is your work on a project, whether the sponsor pays your salary or not.
• When you write yourself into a grant proposal, you are committing your effort to the sponsor.
• If you reduce your effort, paid or cost-shared, on a federal grant by 25% or more, you must have agency approval. If you reduce your paid effort, you may choose to document cost-sharing so that the total effort does not decrease.
• Many activities cannot be charged to a federally sponsored project. For example, the time you spend on the following activities cannot be charged:

1. Writing a proposal
2. Serving on an IRB, IACUC or other research committee
3. Serving on a departmental or university service committee

• If you work on a sponsored project, you must certify your effort.
• Certifying effort is not the same as certifying payroll
• Certification must reasonably reflect all the effort for all the activities that are covered by your UMASS compensation.
• Effort is not based on a 40-hour work week.
• Effort must be certified by someone with a suitable means of verifying that the work was performed.
• Any indication that certification was based on factors other than actual, justifiable effort is a red flag for an auditor.

A word about terminology

Strictly speaking, graduate students receive stipends rather than salary. In this course, the term salary is used to refer to both salary for employees and stipends for graduate students.

Go Back to Effort Certification page

The Basics of effort and sponsored projects

What is "effort"?

Effort is the time you spend on an activity, expressed as a percentage of all the time you spend on your UMASS job duties.

Your UMass job duties may include:

• Instruction
• Administration
• Research
• Service as a member of a committee or governance body
• Outreach to the community

A sponsored project is activity that is funded by a grant, contract, or cooperative agreement under which there is a scope of work, a specific budget, and specified terms and conditions. It requires detailed financial accountability and compliance with the sponsor's terms and conditions. In this course we'll focus on effort associated with sponsored projects and the relationship of that effort to your non-sponsored activities.

What is effort certification?

If you work on a sponsored project, you're required to assure the sponsor that:

• You did, in fact, devote effort to the project at a level that corresponds with how you were paid from the project, and
• You've met your commitments of effort to the project, regardless of whether the sponsor provided salary support.

Effort certification is the university's means of providing this assurance to sponsors.

To certify your effort, you'll review a statement that shows:

• The sources from which you were paid, and
• Your cost-shared effort on sponsored projects

Your task is to make sure that the statement shows a correct distribution of your effort.

This requires a good understanding of many things, including:

• Cost-shared effort
• Commitments to sponsored projects
• How to classify the things that you do, so you can sort them into buckets for the purpose of determining your effort distribution

In this course, the terms effort certification and effort reporting are used interchangeably.

Effort certification is not an exact science

Don't worry – you don't need to come up with a precise accounting of your time. Sponsors recognize that research, teaching, service, and administration are often inextricably intermingled.Reasonable estimates are all that's expected. But there are some rules you must observe.

Certifying 100% of your UMass effort

If you work on a sponsored project, what's important is the effort on that project in relation to your other effort. This leads us to the first rule: You must certify 100% of your UMass effort.

The next module explains what we mean by UMASS effort, as opposed to non-UMASS effort.

Effort is not based on a 40-hour work week

This is one of the most common misconceptions about effort on sponsored projects. Regardless of your appointment percent or the number of hours you work, your 100% effort equals all the activities for which you are compensated by the university – your total UMass effort.

Examples

• If you have a quarter-time job, your 100% effort corresponds to everything you do for that job. So, for you, 0.25 FTE = 100% UMass Effort
• If you work 80 hours a week, your 100% effort corresponds to all the activities for which the UMass compensates you during that time. Here, 80 hours = 100% UMASS effort

This may seem counterintuitive, but it stems from cost accounting anomalies that would arise if 100% effort corresponded to a 40-hour work week and you worked more than 40 hours in a week. For example, let's say you devote 30 hours a week to sponsored projects and 30 hours a week to teaching. Under the traditional "40 hours equals 100%" rule, you're working 150%. If you divide your activity as 75% teaching and 75% sponsored research, then you've carved your 100% effort and related salary into more pie pieces than you have available.

If, alternatively, you were to charge 75% of your salary to sponsored projects and 25% to university funds, your compensation per hour of sponsored research is three times your compensation per hour of teaching. That's a disproportionate charge to sponsored projects because the amount of time spent on each activity was the same. This violates federal regulations that govern how the university charges a sponsor for salary expenses. So, no matter how you slice it, cost accounting standards make it impossible to base effort on a 40-hour week.

Sponsored and non-sponsored activities

If you teach a class and work on a research project, you're probably aware that you can't charge your teaching time to your sponsored project. The time you spend on your research project is sponsored activity. Classroom instruction is an example of a non-sponsored activity. Sometimes it's hard to know whether to classify an activity as sponsored or non-sponsored. For example, mentoring a graduate student is sponsored activity only if the mentoring is specific to a research project. Otherwise, it's instruction – a non-sponsored activity. The federal government is very specific regarding the activities that are allocable to sponsored projects.

This leads us to a second rule: When determining your effort distribution, you must distinguish between activities that are allocable to sponsored projects and those that are not.

The next module provides more details about this.

Putting it all together

The diagram below illustrates the net effect of these two rules. In this diagram:

• The pie chart represents your UMass effort – the activities for which you are compensated by the university.
• This pie is divided into only two pieces: the activities that are allocable to sponsored projects, and those that aren't

If you work on multiple sponsored projects, you'll subdivide the sponsored piece into two or more slices – one per project.

In short, effort certification is largely about being able to answer two key questions:

1.      How big is your pie?
2.      What's the relative size of the slices?

2. UMass Effort and activities sponsored projects

What counts as UMD Effort?

Because you must certify 100% of your UMD effort, it's important to know what counts as UMD effort and what doesn't.

The basic rule is:

Your UMD effort includes all the professional activities for which you are compensated by the university.

Specifically, it includes the following:

1. Externally sponsored research, including all activities that the federal government recognizes as allocable to sponsored projects
2. Departmental and university research that is not funded by an outside source
3. Instruction and university supported academic effort.
4. Administration, including your role as department chair, program director, or dean
5. Service on institutional committees such as IRBs, IACUCs, and governance bodies
6. Effort expended on preparing proposals for new or continuing sponsored projects
7. Activities related to pursuing intellectual property
8. Public service activities directly related to UMD professional duties
9. Outreach activities that directly relate to UMD professional duties
10. Paid absences, including vacation time and sick leave

When you receive compensation from someone else, the activity is not part of your UMD effort. In addition, some other uncompensated activities do not count as UMD effort.

Specifically, the activities you should not count as part of your total UMD effort are:

• Consulting outside of the UMD
• Continuing Education Courses
• Advisory activities for sponsors, such as service on an NIH study section or NSF peer review panel, regardless of whether you are compensated in any way
• Peer review of manuscripts, regardless of whether you are compensated
• Leadership in professional societies
• Volunteer community or public service not directly related to UMD effort
• Lectures or presentations for which you're compensated by a source other than the UMD
• Other special activities resulting in a payment of a bonus or other one-time extra compensation
• Activities over and above or separate from your assigned responsibilities in your primary position, including service as the primary editor of a journal
• Unpaid absences

Activities that can be allocated to a sponsored project

Your sponsored effort is part of your UMD effort. When you certify sponsored effort, it’s important to know what activities can be allocated to a sponsored project. The basic rule is:

A sponsored project can only be charged for activities that directly relate to the work of the project.

Here are some specific activities that can be charged to sponsored research:

• Directing or participating in any aspect of the research related to the specific project
• Writing a progress report for the project, sometimes called a continuation proposal
• Holding a meeting with lab staff to discuss the specific research project.
• Activities contributing to and intimately related to work under the agreement, including:
  
  • Participating in appropriate seminars
  • Consulting with colleagues about specific aspects of the project
  • Delivering special lectures about specific aspects of the ongoing activity
  • Attending a scientific conference held by an outside professional society to present research results
  • Reading scientific journals to keep up to date with the latest developments in one's field Mentoring graduate students on the specific research project
• Making an invention disclosure, and some other activities related to pursuing intellectual property – as long as it is directly related to the project and the effort occurs within the project award period

Activities that cannot be allocated to sponsored projects

Here are some specific activities that cannot be charged to a sponsored project because they do not directly relate to the work of the project:

• Proposal-writing, except for non-competing continuations (progress reports); this includes:
  • Developing necessary details to support the proposal
  • Writing, editing and submitting the proposal
  • Administration, including service as a department chair or dean
  • Instruction, office hours, counseling for students, and mentoring graduate students on something other than a specific research project
  • Service on an IRB, IACUC, selection committee, or other similar group
  • Course or curriculum development not specific to your research project
  • Writing textbook chapters
  • Fundraising
  • Lobbying

In addition, work that falls outside of the definition of UMD effort would not be allocated to a sponsored project. This includes:

• Service as the primary editor of a journal
• Peer review of manuscripts, regardless of whether compensation is received
• Advisory activities for sponsors, including service on an NIH study section or NSF review panel, regardless of whether compensation is received

Examples of specific activities and how to classify them

From the above lists, a few items deserve special mention:

Type of activity

1. Writing a proposal for a new sponsored project or competing continuation: You cannot charge a sponsor for your time spent doing this. You must count this as a non-sponsored activity. It falls under the heading of administration.
2. Mentoring students: When the mentoring is specific to a sponsored project, this is a sponsored project activity. When the mentoring is of a general nature, or specific to something other than the sponsored project, you cannot count it as a sponsored project activity.

Effort that's too small to count

• Activities that you do on an infrequent, irregular basis are sometimes "so small" that they cannot (and should not) be accounted for. In any calculations of effort, you can ignore these activities when they add up to less than one percent of your total UMD effort.
• Activities that may qualify as de minimis effort – depending on their nature and extent, and on the amount of time you devote to them relative to your total UMD effort – include service on an ad hoc committee (like a search committee) and participating in department or division meetings.
• In addition, some activities are intrinsic to your daily routine and not separate from your teaching, research, administrative, or other duties. Requesting your parking sticker and submitting a travel expense report are examples of such activities. Do not count these in a separate
  category of effort. Grant proposal writing and well-defined, regular administrative or service activities cannot be considered "so small" and therefore don't qualify as de minimis effort.

True UMD activities cannot be characterized as unfunded, volunteer, or weekend work

Activities that are closely associated with your UMD professional duties must be reported as UMD effort.
Some of those activities are:

• proposal writing
• instruction
• university-related administrative duties
• service on committees

You cannot characterize them as "unfunded" or "volunteer" activities, or "weekend work," for which no UMD salary is paid, because federal regulations prohibit this.

3. Commitments to sponsored projects

Three key terms: Cost sharing, cost-shared effort, and paid effort

Often, the sponsor pays all of the costs associated with a sponsored project. But sometimes UMD bears a portion of the costs.

1. Cost sharing is the portion of the total costs that is borne by UMD rather than by the sponsor.
2. Cost-shared effort is any work on a sponsored project for which the university, rather than the sponsor, provides salary support.
3. Paid effort is work for which the sponsor provides salary support.

Both types of effort are important in the effort certification process.

What is a commitment?

A commitment is the amount of effort you propose in a grant proposal or other project application, and that the sponsor accepts – regardless of whether you request salary support for the effort. Commitments are specific and quantified, and they generally are expressed in terms of a percentage of your work time over a given project period.

Example

If you indicate in a grant proposal that you will devote 30% of your effort to the grant for one year, and request salary support for 10% of your effort, then

• The effort commitment is 30%
• Paid effort is 10%
• The cost-shared effort is 20%

A commitment is an obligation that the university must fulfill. Commitments may be adjusted with the approval of the sponsoring agency.

Are effort commitments recognized and tracked for all project personnel?

Commitments are recognized and must be tracked for:

• the principal investigator/project director, and
• all co-investigators, and
• all persons identified as senior/key personnel in the grant proposal.

When the proposal does not explicitly list key persons, the university defines key personnel for the purpose of effort reporting as the principal investigator/project director and all co-investigators.

What statements in the proposal form the basis for commitments?

Requests for salary support and statements about cost-shared effort in the budget or budget justification become binding commitments when the university and the sponsor finalize the award agreement.

When effort proposed in the project description or research plan is specific and quantified, it also becomes a binding commitment at the time the university and the sponsor finalize the award agreement.

Example

"Professor Jones will devote 10% of his time during the academic year to this project."

Even if Professor Jones is not mentioned in the budget or the budget justification, this statement represents a specific, quantifiable commitment to the sponsoring agency.If a statement in the project description or research plan is not specific and quantified, such as "Professor Jones will provide some assistance as needed to the project," it does not become a binding commitment.

Limits on your total effort commitments to sponsored projects

No one can ever have commitments to sponsored projects that total more than 100%.

Your commitments to sponsored projects can add up to a full 100% only if all of your UMD job duties can be allocated to sponsored projects. Faculty members generally have academic or administrative responsibilities in addition to their work on sponsored projects. Consequently, a faculty member's commitments to sponsored projects generally cannot total 100% for any consecutive 12-month period.

It is not against the rules for academic staff, classified staff, or postdoctoral researchers to be paid 100% from sponsored projects. There are a number of instances where this is entirely appropriate, given the individual's job duties. However, everyone's allocation of effort to sponsored projects must be reasonable in light of their non-sponsored university activities.

The PI's minimum commitment of effort to a sponsored project

An effort commitment is required of the principal investigator/project director (PI/PD) for every federal and non-federal sponsored project. This includes fixed-price agreements, where the commitment may not be stated explicitly. In such cases, the commitment is implicit in the reimbursement negotiated with the sponsor.

A PI/PD is responsible for the scientific, administrative, and financial management of a sponsored project. Fulfilling these responsibilities requires time and represents a commitment of effort.

This doesn't apply for equipment and instrumentation grants, doctoral dissertation grants, or student augmentation grants. It does apply for the PI/PD on a training grant, but not for the faculty mentors (also known as preceptors or program faculty) as their effort will be assigned to the trainees' specific research projects.

4. The basics of effort certification at UMass

The remaining modules make several references to the term effort coordinator– an individual that reviews each certification and assists faculty and staff with the process of certifying effort.  UMD has one primary effort coordinators in ORA.  The primary effort coordinator will review and process the final certification statements.

Whose effort must be certified?

Effort must be certified for all UMD faculty, staff, students, and postdoctoral researchers who either:

1. Charge part or all of their salary directly to a federally funded sponsored project, or
2. Expend committed effort on a federally funded sponsored project, even though no part of their salary is charged to the project

Who certifies for whom?

Effort must be certified by a responsible person with suitable means of verifying that the work was performed. This is a federal requirement. It is never acceptable to circumvent this rule.

Each principal investigator certifies the effort for the professional staff, graduate students, postdoctoral researchers, and classified staff who work on his or her research projects.

Sometimes the PI doesn't have a suitable means of verifying the effort for all the people who work on a project - and someone else, like a lab manager, does. In such cases, the PI and the effort coordinator can work together to establish a designee's authorization to certify for project staff members.

Sometimes a staff person works on multiple projects for two or more PIs. In such cases, each PI certifies the staff persons effort related to the PIs particular project(s).

When must effort be certified?

Effort must be certified annually.

The period of performance that you will certify is September 1 to August 31.

The time during which you certify effort is called the certification window. The certification window begins a month or more after its corresponding period of performance.

Each time a certification window begins, you will have approximately six weeks to certify the effort for the corresponding period of performance.

Consequences of untimely certification

Timely effort certification is a mandatory federal compliance requirement, and failure to certify on time carries serious ramifications at both the individual and institutional levels:

• Individual PI Level: Uncertified effort can result in salary charges being deemed unallowable, requiring retroactive removal from the grant and direct cost transfers to non-sponsored departmental or PI funds. Furthermore, continued non-compliance may lead to administrative holds from the Office of Research & Innovation, including the suspension of proposal submissions, withholding approval of hiring or re-appointment actions, and pausing subsequent award setups, amendments, or re-budgeting requests for that PI.
• Institutional Level: Late or missing certifications violate Uniform Guidance standards, exposing the university to severe audit findings, mandatory repayment of federal funds, and administrative penalties. Repeated compliance lapses jeopardize our federal standing and can lead sponsors to withhold future award notices, freeze payment drawdowns, or impose heightened institutional oversight across all sponsored projects.

Recertification

If you think you have certified effort incorrectly, contact ORA to ask about recertifying.

Once the last date of the certification window has passed, a subsequent recertification can call into question the reliability of the certification process. Therefore, your request must explain why the effort was erroneously certified, and why the requested change is more appropriate within the context of law, federal requirements, or University policies and procedures. Your written request will be reviewed by the Director, Office of Research Administration. Only in the most compelling of circumstances will it be approved.

How to certify effort

Use the Web-based ECC system to certify effort for faculty, full-time staff, postdoctoral researchers, and graduate students.

For student and part-time hourly workers, the timesheet serves as the mechanism for certifying effort.

ECC cannot be used to certify the effort for some individuals. This includes:

• Faculty and staff with zero-dollar, zero-percent appointments
• Some faculty and academic staff members who have left the university

Modules in this course describe how to certify with ECC. If you cannot certify your effort with ECC, contact your effort coordinator or ORA with questions about how to certify.

Certifying effort versus certifying payroll

Your effort statement shows, for a specified time period, the sources from which you were paid and the percent of your salary that was charged to each source. This payroll information is an important building block of the effort statement. But it's not the only thing you should think about when certifying your effort.

It would be a mistake to think of the effort certification process as "confirming that this is how you were paid by the university." Remember that when you certify effort correctly, you are providing an assurance to the sponsor that:

The university's salary charges are reasonable, given the work that was performed, and

Faculty and staff have met their commitments to sponsors, regardless of whether the university requested salary support for the effort.

For some people, this will require a change of mindset. The next module describes some things to consider when determining your effort distribution and certifying effort.

5. Effort certification guidelines

The effort statement

The image below shows an ECC effort statement.

The top part of the effort statement shows administrative detail including the name of your Effort Coordinator. Please note that sponsored project financial administrators have also received ECC training and can be used as a resource for questions.

The next part of the effort statement shows information about sponsored projects. Each line represents a project from which you were paid, or a project to which you might have devoted cost-shared effort.
On the bottom half of your statement, your non-sponsored activities are shown.

Reading across the statement, the six columns are:

Column name and what it means

• Accounts - For sponsored activity, the fund, project account, abbreviated title and sponsor name is shown. For non-sponsored activity, the fund, account number and title are shown.
• Required Effort - The commitment of Effort reflected in the final accepted budget and made a part of the award. This field is automatically populated through the PeopleSoft grants module.
• Payroll- Payroll distribution for the certification period. This field is automatically populated through the PeopleSoft financial system
• Cost Share - Cost sharing information for the period of performance. This field is populated through the Office of Research Administration.
• Computed Effort - The sum of the payroll percentage and the cost sharing percentage from each line.
• Certified - The text boxes are populated automatically to equal the computed effort box. The text boxes may be overwritten to allow the PI to enter the effort percentage should the actual effort differ significantly from the percentage shown.
• Certify - Check boxes that you must check to certify your effort for each line on the statement.

How paid effort is represented on the effort statement

Each statement is specific to a period of performance. If the sponsor provided salary support for your effort on a project during the period, you will see a positive number in the Payroll column for the corresponding project. For the purpose of effort certification, sponsored projects include all sponsored activity administered through the Office of Research Administration. The account number always begins with a leading “S”.

If you received salary support from any source other than a sponsored project during the period, you will see a positive number in the Payroll column in the non-sponsored, bottom half of your statement.  Non-sponsored activity includes: State Maintenance payroll; Operating Fund payroll; non-sponsored projects, e.g., the Healy grants or CVIP grants.

Cost-shared effort and your effort statement

When you certify your effort, you must include your cost-shared effort up to and including the amount of your cost sharing commitments.

In the example below, the following effort card is displayed at login The sponsored program activity highlighted reflects: Required Effort of 20%; Computed Effort (Payroll Column + Cost Share Column) of 13.48% and Certified Effort of 13%.  Assume for this certification period, the Principal Investigator has contributed 20% effort on this project. The difference between the required effort of 20% and the computed effort of 13% is cost-shared effort of 7%.

The revised effort card is shown below. Note that the PI increased certified effort from 13% to 20%. Also note that non-sponsored project effort was reduced from 73% to 67% to reflect the 7% of cost-shared effort attributable to the sponsored program.

 

Committed effort versus extra effort

Perhaps you've spent more time on a project than you were paid to spend. Or you've put in extra effort, over and above your cost sharing commitment. This is called voluntary uncommitted cost sharing. Any extra effort, above what is stated in the award agreement, is not required to be documented, tracked, or audited. You should not include it in the effort you certify for a sponsored project.

How to determine your effort distribution

Before certifying effort, you should determine your effort distribution. The steps in doing this are:

1. Consider all of your activities for the period of performance.
2. Determine which activities are allocable to your sponsored projects, and which are not.
3. Group your sponsored activities by project
4. For each sponsored project, determine what percent of your effort for the period you devoted to the project.
5. Adjust non-sponsored activities to accurately reflect cost-shared commitments. If you have multiple non-sponsored activity accounts, the adjustment can be made against the State Maintenance or Operating Fund account

Remember that effort certification is not an exact science, and you are not required to come up with precise numbers. Reasonable estimates are acceptable. The goal is to be able to explain your activities and so confirm, if asked, that your work justifies the salary charges and meets your commitments to sponsors.

Reasonable estimates and the degree of tolerance

Federal regulations allow for an acceptable variance between the actual effort for a sponsored project and the effort as certified on the statement. At the UMD, this variance is defined as five percentage points out of your 100% total UMD effort.

Example

Your commitment to a project is 50% of your UMD effort. And for a given effort period, 50% of your salary was charged to the project. Your effort statement reflects this. Therefore, it is permissible to certify 50% effort for this project if your reasonable estimate of your actual effort is between 45 and 55 percent of your total UMD effort.

Why? The federal government expects only reasonable estimates of effort, and allows for a degree of tolerance in certifying effort. And, in fact, certifying this way is not only permissible but the recommended practice.

Assume for a moment that you are paid 100% from sponsored project funds and you have more than a de minimis amount of non-sponsored activity. Does the five percent rule justify certifying 100% of your effort as sponsored effort? The answer is no – it does not create headroom for non-sponsored activities up to five percent of your total UMD effort. A certified effort report is your best reasonable estimate of how you expended effort. Everyone acknowledges that an estimate may be slightly off. This is different from knowingly misrepresenting non-sponsored activities as sponsored effort.

6. Effort reporting: how to certify your effort with ECRT

How do I know when to certify?

• UMass Dartmouth certifies effort on an Annual basis.
• the Certification will cover the previous Fall, Spring and Summer sessions.
• You will be notified via a system generated email when it is time to certify.

How do I certify my effort?

1. Log onto UMASSD.EDU
2. Go to MYUMASSD
3. Under “Quick Launch” pick ECC System.
4. This will bring you to the Welcome screen
5. Hit the Continue button

6. You will be brought to your work list. Click on your name

• • Here is an example of an effort card. It is broken out in two different segments. The top is Sponsored Effort and the bottom is Non-sponsored Effort.

Commitments column

The Commitments column details the percentage of effort you committed to each project for the certification period. It is imported directly from PeopleSoft, which is based upon percentages allocated to each award.

If there is a difference greater than 5% between committed effort and certified effort, an explanation
must be added in the Notes section.

Payroll and cost share columns

The Payroll Dollars column lists the payroll dollars charged to each project during the certification period.

The Payroll column details the percentage of effort calculated based upon the payroll dollar amount expended for the certification period. These details are imported directly to ECC from PeopleSoft.

The Revised Cost Share is used by the Effort Coordinator to Include Cost Share. All Cost Share effort is detailed in the Non-Sponsored section and entered by ORA per the award cost share commitment.

Computed effort and certified effort columns

Computed effort is what the system has calculated based upon your payroll data. You are able to adjust in the Certified Effort column if your effort was different for the certification period. If the variance between the Computed column and Certified Column is greater than 5%, a note must be added to the card

In this case, the Certifier moved 3% of effort from the Non Sponsored line to the last project on the Sponsored section. Since the total must equal 100%, certified effort for Non Sponsored must be reduced by 3% to now equal 81%. The PI should add a note in the notes section to account for the change in effort. (Notes are required for changes in excess of 5%).

After any changes be sure to click the Save on the bottom right.

Adding a note or attachment

• To add a note, click on the icon next to Notes. A box will pop up where you can record any pertinent information.
• If you wish to attach a file, click on the icon next to Attachments. You will be able to browse your folders and attach.

Certify? column

If the amounts in the Certified Effort Column are accurate, click the boxes. (Effort must equal 100%)

Click the Save button and then the Certify button.

After you hit the Certify button, you must wait for this window to pop up and then hit the I Agree button.

How do I certify my employees' effort?

After you certify, your screen will default to the next name on your worklist.

You only need to check the Sponsored Effort Certify box. Then follow the same procedure as detailed for PI certification.

Key points

• Effort must equal 100%.
• Any manual changes to certified effort should have an explanation recorded in the Notes section.
• If you have any questions or issues, please contact Catherine Palmer in the Office of Research Administration at cpalmer1@umassd.edu

7. Managing effort while working on your projects

The emphasis thus far has been on preparing you to certify effort. Now we want to highlight some additional important issues.

In this module we explore the interplay between your effort commitment, your actual effort, and your salary charges during your work on a project. Six key principles are:

1. You are required to fulfill your effort commitment for each sponsored project budget period.
2. During a sponsored project budget period, your actual level of effort may vary.
3. Except for short term fluctuations, your salary charges must be consistent with your actual effort.
4. If you wish to change your commitment, you must always document the change and in some circumstances you must obtain prior written approval  from the Sponsor.
5. If you maintain your commitment level and your actual effort but reduce your salary charges to the grant, you must document this increase in your cost shared effort.
6. If you receive an award from the sponsor and the budget is significantly less than you proposed, you must decide how you will conduct the project an then confirm this with the sponsor-because the sponsor does not assume a proportional reduction of effort commitments.

This information is intended primarily for PIs, but the principles are important for all certifiers.

Effort variations within a sponsored project budget period

During the course of a sponsored project budget period, your level of effort may vary. This is acceptable, as long as you fulfill the overall commitment for the entire budget period.

When does a change in effort require prior approval from the sponsor?

The rules depend on the type of change and your role on the project. First, the federal government defines a significant change in work activity as:

• A 25 percent (or greater) reduction in the level of committed effort
• An absence from the project of three months or more
• A withdrawal from the project

For a principal investigator/project director as listed in the Grant Award

• A significant change in work activity requires prior approval in writing from the sponsor's Grants Officer. It is not okay to just communicate the change to your Program Officer.
• Any other change in your level of committed effort must be documented and communicated to the sponsor

Example

Your committed effort is 40%, and you want to reduce it to 30%. The drop is 25 percent of your original effort commitment, so it requires prior written approval from the sponsor.
For a key person as identified in the proposal who is not listed in the Grant Award:

• Any change in your level of committed effort must be documented

For individuals who are not key personnel, commitments are not recognized and changes to effort levels need not be documented or communicated to the sponsor.

Changing the salary charged to a sponsored project

PIs generally have some flexibility in managing their sponsored project budgets, including their salary charges for project staff. However, this rebudgeting authority does not confer the right to:

• Make significant changes in work activity without prior approval from the sponsor, or
• Change effort commitments for key personnel without documenting the changes

Furthermore, if you reduce a person's salary charges without changing the effort commitment, that's an increase in cost sharing and should be documented as such.

Taken together, the rules regarding changes to salary charges and commitment levels are somewhat complex. They're summarized below, but you don't need to memorize them; the specifics are always available on the ORA Web site. For a significant change in work activity, documenting the change means communicating it to ORA after getting the sponsor's approval. For all other changes, documenting means maintaining a written or emailed record at the department level.

For an principle investigator

If  you want to – then you must:

• Reduce the salary charges without changing the effort commitment-- Document as cost sharing the effort for which the sponsor will not provide salary support
• Reduce both the salary charges and the effort commitment by less than 25% of the original commitment level-- Document the change to the commitment level
• Reduce both the salary charges and the effort commitment for a key person as listed in the grant by 25% or more of the original commitment level-- Obtain approval from the sponsor prior to the change and in writing, and document the change to the commitment level when approved

Reduce both the salary charges and the effort commitment for a key person listed in the proposal but not in the grant by 25% or more of the original commitment level-- Document the change to the commitment level

For a project staff member who is not an investigator or key person

If  you want to – then you must

• Reduce the salary charges without changing the effort -- Document as cost sharing the effort for which the sponsor will not provide salary support
• Reduce the salary charges and the effort by commensurate amounts -- No documentation, notification, or approval is required

When the awarded budget is less than proposed

If you receive an award from a sponsor and the budget is less than you proposed, you cannot assume that your effort commitments are automatically reduced by a proportionate amount. You may need to confirm the effort commitments and the arrangements for salary support with the sponsor.

You have three options:

1. Reduce the effort commitments in proportion to the budget reduction. With a budget reduction of 25% or more, you must request approval from the sponsor for this option. A reduction of that magnitude (10% or greater on an NSF award) generally indicates a project scope reduction, so a proportionate reduction of effort commitments would be appropriate.
2. Keep the proposed effort commitment and salary arrangements, and reduce expenditures in non-salary budget categories.
3. Keep the proposed effort commitments but reduce the salary charges. This increases the university's voluntary cost sharing for the project, and must be explicitly approved in accordance with your college or school's policies on cost sharing.

No-cost extensions

The terms and conditions of your award apply throughout the project period, including a no-cost extension period. This includes the PI's effort commitment. At the same time, federal agencies realize that PI effort may be reduced during no-cost extensions as the project is winding down, or when data analysis requires additional time.

While this is not considered a change in scope, it is in the best interests of the institution and the PI to notify the sponsor of this decrease in effort to avoid discrepancies with current and pending support statements, effort certification, or issues of research overlap.

8. Course wrap-up

Your next steps

Once you complete this course, you're ready to certify your effort – and the effort for your project staff.

Before doing so, you may wish to refresh your memory about your activities. You can log into ECRT and view an effort statement at any time, without having to certify. From the effort statement, you can view a summary of each sponsored project. The summary page shows the project's start and end dates and a list of the people with paid or cost-shared effort on the project.

Where to go for additional information

The Time & Effort page on the UMD Website contains links to many helpful resources.

The information you'll find there includes:

•  the university's policy on effort certification
•  answers to frequently asked questions
•  presentations on selected topics

If you have questions, you might wish to contact one or more of the following:

• Your effort coordinator
• Your financial administrator

Where to go for help

Your effort coordinator is always the first place to go for assistance. In ECRT, your effort statement contains a link to your effort coordinator's email address.