Current through all regulations passed and filed through September 16, 2024
(A) Purpose
The university must ensure payroll costs, example, salary,
wages, stipends and fringe benefits, that are charged to sponsored programs
adhere to the effort reporting standards
in the office of management
and budgets ("OMB") uniform guidance 2 C.F.R. 200Sec tion
200.430.
(B) Scope
This rule applies to all faculty, staff, students, and fellows
with payroll charges or effort commitments on sponsored programs if they are
paid directly by the sponsored award or cost-shared from other funding
sources.
(C) Definitions
Consult rule
3349-7-01 of the Administrative
Code.
(1) "Actual Effort" is the
actual effort expended on a sponsored program; and is usually expressed as a
percentage of total effort.
(2)
"Cost Sharing of Effort" is the portion of total effort not paid by the
sponsor. For example, twenty per cent effort commitment with a request for
fifteen per cent salary support results in a five per cent cost sharing
commitment.
(3) "Effort Commitment"
is the proportion of effort proposed by faculty, staff, students or fellows to
carry out their stated role on a sponsored program. This can be expressed as a
percentage or in person months. The terms "effort commitment" and "committed
effort" are interchangeable.
(4)
"Institutional Base Salary" is the annual compensation paid by the university
for an individual's appointment, whether that individual's time is spent on
research, instruction, administration, or other activities. Institutional base
salary excludes any income that an individual earns outside of duties performed
for the university.
(5) "Principal
Investigator" refers to the faculty or staff member designated by the sponsor
to have the appropriate level of authority and responsibility to direct the
project or program supported by the grant.
(6) "Person Months" is a method of expressing
effort percentage by normalizing an individual's effort percentage compared to
their appointment length, which may be a partial year appointment. For example,
an individual with a twelve month appointment devoting twenty per cent effort
would be working 2.4 person months (calculated by multiplying twenty per cent
times twelve months equals 2.4 person months). Many federal sponsors require
effort commitments to be proposed in person months.
(7) "Significant Reduction in Committed
Effort" is defined as a variance greater than twenty-five per cent between
committed effort and anticipated actual effort. For example, a personal
investigator with a twenty per cent effort commitment who anticipates only
being able to devote ten per cent effort would have a significant reduction in
committed effort, calculated by the following: (effort commitment less
anticipated effort) divided by effort commitment or numerically: (twenty per
cent - ten per cent) / twenty per cent equals fifty per cent reduction in
effort, which is greater than twenty-five per cent and may require sponsor
approval prior to reducing effort.
(8) "Total Effort" is the sum of all effort
expended or planned to be expended for a period ; this includes all activities for which an individual is paid
their institutional base salary. The total effort calculation is based on the
time necessary to fulfill one hundred per cent of activities for which an
individual is compensated, regardless of the number of hours worked; it is not
based on a forty hour work week.
(D) Rule statement
(1)
The OBM uniform
guidance standards state that effort reporting must:
(a)
Be supported by a
system of internal control which provides reasonable assurance that the charges
are accurate, allowable, and properly allocated.
(b)
Be incorporated
into the official records of the university.
(c)
Reasonably
reflect the total activity for which the employee is compensated by the
university, not exceeding 100% of compensated activities.
(d)
Encompass both
federally assisted, and all other activities compensated by the
university.
(e)
Comply with the established accounting policies and
practices of the university.
(f)
Support the
distribution of the employee's salary or wages among specific activities or
cost objectives if the employee works on [multiple] award[s] or activities
regardless of the source of funding.
(g)
Correspond to the
actual charges for salaries and wages rather than be based upon budget
estimates alone which do not qualify as support for charges to federal
awards.
(2)
Effort commitments are expressed in
percentages or person months when proposed to the sponsor. Once the proposal is
awarded, those effort amounts become effort commitments that must be met within
a reasonable variance (example, +/- twenty-five per cent change between
committed effort and actual effort).
(3)
Key personnel, which includes the principal investigator, coprincipal
investigator, or other individuals named in the notice of grant award or
contract, are typically required to request prior written approval from the
sponsor when they anticipate a significant reduction in effort (example, a
twenty-five per cent reduction in effort or a twelve week absence).
(4)
University employs an electronic after-the-fact
effort certification method which requires payroll
distributions to be updated on a continual basis to account for new awards or
changes in effort with actual effort being certified on a semi-annual basis on
time and effort certification reports.
(5)
Sponsored programs will be separately identified on the time and effort
certification reports with payroll charges expressed as percentages of payroll
charged to the sponsored program in relation to the
institutional base salary during the certification period.
(6)
Time and effort certification reports must list all cost
sharing of effort for the certification period.
The sponsored program and
cost sharing effort are
listed as
payroll charges , the total of the two combined funding sources is
representative of the total effort for the project requiring
certification.
(7)
Time and effort certification reports
must be certified by an appropriate individual.
(a) Faculty who are principal investigators
may certify their effort for their own awards.
(b) All other individuals must have their
effort certified by
(i) The named employee on
the time and effort certification report; or
(ii) The principal investigator(s) for the
sponsored program(s) that appear on the time and effort certification
report.
(c) In special
circumstances where an individual has terminated employment, is on an extended leave of absence, or not
accessible, the following individual(s) may be
appropriate
to certify that individual's time and effort certification report:
(i) The principal investigator(s),
or
(ii) Named employee's
supervisor, or
(iii) Department
chair, or
(iv) Another responsible
institutional official who has suitable means to verify the work was performed
during the certification period. Proper documentation must accompany the time
and effort certification report to justify the appropriateness of the alternate
certifier.
(8)
The certifier is responsible for reviewing all payroll lines on the time and
effort certification report and certifying that the payroll percentages charged
to each sponsored program (paid and cost-shared) and all other activities
reasonably agree with how the employee devoted their actual effort during the
certification period. Department administrators who
support the certifier(s) in the financial management of their sponsored
programs may be granted "viewing access only" to assist certifiers with the
review process.
(9)
Supplemental earnings for duties
outside of an individual's primary appointment (or job duties) for which they
are paid an institutional base salary are not included on the time and effort
certification report.
(10)
All sponsored program activities must be
reported on the time and effort certification report. This includes all cost sharing
commitment and situations where the notice of award has not been issued, an
index number has not been established, or payroll distributions have not been
updated in time to be reflected on the time and effort certification
report.
(11)
An individual's payroll distribution
must be directly correspond to the time and effort certification report
before certification
.
(12)
Effort expended
may exceed the amount charged to an award. However, the amount charged cannot
exceed the effort expended nor the effort committed to the sponsor in
accordance with the terms of the sponsored programs.
(13)
The time and effort certification report cannot be adjusted once certified,
unless the adjustment is to reduce overstated effort.
(E) Responsibility
(1) Principal investigator is responsible for
adhering to this rule in its entirety.
(2) Office of research and sponsored programs
is responsible for evaluating effort commitments at the proposal and award
stages.
(3) Grants accounting is
responsible for generating and tracking time and effort certification
reports.