Effort Reporting and Certification Policy

EFFORT REPORTING

Basics of Effort Reporting and Certification

Basics of Effort Reporting and Certification Introduction

This module reviews the importance of effort reporting and the process of effort certification at UNH. It is required training for all Faculty, Operating Staff (OS), Professional, Administrative and Technical (PAT), Extension Educators (EE) with any salary paid from sponsored programs. Graduate students, adjunct operating staff, and others who support sponsored projects are encouraged, but not required, to complete this training.

UNH Sponsored Programs Administration (SPA) developed this training and is responsible for ensuring compliance with policies and regulations from external sponsors.

Please review these materials carefully and answer the review questions at the end of each section. Certify completion of this training on the last page.

Course Goals

Gain a working knowledge of:

Basics of Effort Reporting and Certification

Effort is…

Effort Certification is a means of assuring sponsors that your level of effort, expressed as a percentage of total university effort, corresponds to the amount you were paid from the project. This assurance process is required by UNH policies and federal regulations.

This is accomplished through your effort report and certification. The effort report includes all funds from which you were paid for total university effort. The statement will include cost-shared effort as well. All hourly employees certify via the bi-weekly timesheet and do not receive an annual effort report.

University policies and federal regulations require UNH to maintain systems and procedures documenting the distribution of activity, and associated payroll charges, to each sponsored award.

Effort is not…

Effort is not based on a 40-hour work week

This concept generates frequent questions and discussion. Your total university effort is all your activities related to your regular duties, defined in the appointment documents, plus additional pay based on effort that is not incidental. Total university effort is always 100% regardless of the number of hours you work, or whether your total effort is determined to be a full time or less than a full time position.

Example 1 - Your position, and total effort for the university, is defined as a 75% full time equivalent position. You work at least 30 hours per week and some weeks more than 40 hours including time at night and on weekends. Your total university effort is 100%.

Example 2 - Your position is full time however you normally work 80 hours per week. Your total university effort is 100%.

Level of Precision

Federal rules do not define the level of precision in effort certification. An acceptable practice, and one used at UNH, is to require a change in the effort report and the labor cost distributions, when actual effort on sponsored programs varies by 5% or more from the reported effort. Differences of less than 5% do not require labor cost re-distributions unless the associated costs are unallowable such as for effort on preparing competitive proposals.

Level of Precision (continued)

Federal rules applicable to federal grants state that effort reports should "reasonably reflect the activities for which the employee was compensated by the institution."

"... it is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate."

In a few instances, sponsors have asked faculty to keep detailed and precise time sheets to support the level of effort on specific program activities. This practice is unrelated to effort reporting and is not a common business practice for the university.

De Minimus Effort

Some activities are so infrequent and so brief that they cannot and should not be separately accounted for in the effort report but instead should be equitably allocated to sponsored and non-sponsored activities. When reviewing your effort report you can ignore activities that are less than 1% of your total university effort.

Examples of activities that you can consider to be de minimis effort include participation in departmental meetings, annual staff performance reviews, and enrolling in employee benefit plans.

Writing competitive proposals and regular administrative responsibilities, e.g. serving as a department chair, cannot be considered de minimis.

Faculty Compensation

Faculty Compensation - Summer Salary

Faculty with academic year appointments are permitted (under university policies) to accept summer appointments for up to three months of full effort. University related activities (teaching, administrative, and grant writing) reduces the amount of effort that may be charged to sponsored programs in the summer. A request for summer salary indicates a commitment to put forth the comparable effort on the particular project during the summer period. Effort expended during the academic year does not satisfy a commitment related to receipt of summer salary. While personal time off may be taken during the summer period, it is not appropriate to concentrate significant time off during a period for which the faculty member is receiving 3 months summer period salary.

Proposed Contribution of Effort

In preparing proposals, PIs/PDs must propose some level of activity (1% or the minimum required by the program) unless specifically exempted by the sponsor. PIs/PDs are expected by UNH to provide reasonable estimates of the percentage of effort for themselves and all other key personnel necessary to carry out the proposed project.

UNH typically does not cost share/contribute effort on a voluntary basis. Approval for Voluntary Committed Cost Sharing of Effort must be obtained prior to proposal submission from your dean and the UNH Sponsored Programs Administration office. This type of cost sharing is agreed to as part of the award and is required to be documented, tracked, and reported. Voluntary Uncommitted Cost Sharing of Effort is not included in the effort report.

Maximum Allowed Regular Pay

Pay for administrative, instruction, service, clinical activity, institutional governance, and new or competitive proposal preparation must not be charged directly to externally-Sponsored Programs unless the activities are specifically approved activities of those Sponsored Programs. With the proviso that unrelated and unallowable activities may not be charged, a maximum of 95% of a UNH employee's Regular Pay during each fiscal year may be charged to Sponsored Programs. With written approval from the UNH Senior Vice Provost for Research (SVPR), exceptions can be made up to 100% if the employee is working exclusively on Sponsored Program(s).

Proposal Commitments and Overcommitments

It is a common and acceptable practice for combined faculty effort in active and proposed awards to exceed 100% of full time effort with the expectation that not all proposals will be funded. If new funding results in total funded effort commitments that exceed 100%, an adjustment is necessary. In some situations, prior sponsor approval is required.

Prior approval is required from federal sponsors for (1) a change in key personnel or (2) PI/PD absence for more than three months or a 25% reduction in committed effort.

Total University Effort (TUE)

Total University Effort (TUE) is all activities for which you are compensated with USNH-administered funds for performing regular duties and for work effort for which you receive additional pay. Types of additional pay unrelated to effort (e.g., Employee Transition Allowance or monetary awards for recognition) are excluded from consideration for TUE. TUE is 100% regardless of FTE %.

TUE includes all USNH effort-based activities regardless of when during the daytime, evening, weekend, or year, or where (e.g., on campus, at home, while traveling) the activities take place. TUE is not based on a 40-hour work week, but rather on the total USNH hours the employee spends on the combination of Regular Duties and Effort expended for Additional Pay. For example, if a person averages 60 hours per week on USNH activities and spends an average of 15 of the 60 hours per week on a Sponsored Program, that person is spending 25% effort on the Sponsored Program and 75% on other duties.

Not Included in Total University Effort

The following activities are not part of your total university effort and therefore should not be included in your effort report:

Allowable Activities

A sponsored project can only be charged for activities that directly relate to the work on the project. An allowable activity should be solely to advance the work on the particular sponsored project during the performance period.

Specific activities that are allowable include:

Unallowable Activities

Activities that cannot be charged to a sponsored project include:

Question 1

Effort certification is the periodic verification that time and effort allocated to sponsored projects, represented as a percentage of total effort, is approximately accurate in relation to the salary cost allocations to the project.
Correct. Effort certification is the verification that time and effort agree with payroll cost allocations. This is not the verification of just the accuracy of recorded payroll data.
Incorrect.

Question 2

What is the purpose of effort certification?
Correct. Only the first answer is the correct answer. Effort certification is confirmation of time allocations. Effort certification is not a system to collect detailed time allocations or to report leave taken.
Incorrect.
Incorrect.

Question 3

If you work 60 hours per week for a couple of weeks even though your normal work schedule for your position is only 30 hours per week, your total university effort will be 200% during these weeks.
Incorrect.
Correct. Total university effort (TUE) is always 100% no matter how many hours per week you work.

Question 4

When you receive your effort report you notice that the percentage of time allocated to one of your sponsored projects is 10% higher than it should be since other sponsored projects took more time than planned. You should immediately contact your Business Service Center to ask that your labor costs be reallocated to accurately reflect the time and effort allocations before certifying your effort report.
Correct. The level of precision at UNH requires labor redistributions and changes to the effort report when the variance is 5% or greater.
Incorrect.

Question 5

Which of the following could be considered part of total university effort?
Partially Correct. A better answer exists.
Partially Correct. A better answer exists.
Partially Correct. A better answer exists.
Correct. All three are right.

Question 6

Which of the following activities are allowable allocations to sponsored projects? If all are correct then the correct answer is "All of the above".
Partially Correct. A better answer exists.
Partially Correct. A better answer exists.
Partially Correct. A better answer exists.
Partially Correct. A better answer exists.
Correct. All are allowable.

UNH's Certification Process

Whose effort is certified and how?

Each UNH employee must certify, or have certified for them by another responsible person with specific knowledge of the employee’s effort, total university effort, if all or part of the related compensation was from UNH externally sponsored funds. Senior administrators, faculty, PAT (professional, administrative, and technical), extension educators, and graduate students who receive compensation from sponsored funds must certify their own effort, or have certified for them, annually through the online effort system accessed through WISE. Operating staff (hourly based employees) normally certify effort biweekly through Web Time Entry.

Who certifies effort?

Each individual certifies their own effort whenever possible. When it is necessary for you to sign the effort certification for someone else, you must have a suitable means of verification that the allocation of effort is reasonably accurate. There should be evidence available, in case of an audit, to support the suitable means of verification.

How are revisions to effort allocations processed?

When actual effort allocations vary by 5% or more from computed effort allocations, you should submit a written request to your Business Service Center to re-distribute your labor costs and effort percentages. Revisions should be entered as soon as possible to correct reports and billing to sponsors in a timely manner.

Question 7

Who on the following list can certify effort?
Partially Correct. A better answer exists.
Partially Correct. A better answer exists.
Incorrect.
Incorrect.
Incorrect.
Correct. Both A and B are correct and may sign effort certifications. Preferably you should sign your own effort certification as it may be impractical for anyone else to have suitable means of verification of 100% of your effort.

Managing Effort on Sponsored Projects

Budget Reports

Principal Investigators and Project Directors have a responsibility to regularly monitor all labor allocations to their sponsored funds. There are many standard budget reports from the UNH information systems which will provide labor details suitable for monitoring labor allocations.

Significant Changes in Work Activity

Your planned level of effort may vary for short periods of time, such as one or two months, as long as the distribution of salaries and wages is reasonable over the longer term.

Managing Effort Distribution Changes

Because it is expected that the PI/PD will promptly initiate future labor distributions and correct errors to prior salary/labor charges to his/her Sponsored Programs, instances of re-certification of effort after the original certification is filed should be rare. Approval by the UNH SVPR is required in order for UNH to accept a correction of a previously-filed Effort Certification.

Question 8

Your effort on your project activities can vary substantially (more than 50% +/-) during a 3-year project as long as the average total effort agrees with the planned effort.
Incorrect.
Correct. Average actual effort can vary only for short periods of time without instructing your BSC to change the labor cost distribution.

Areas of Caution

Areas of Caution

Congratulations!

Once you have answered all of the questions correctly click “Certify Completion”. You will be reminded to complete this training every three years.

Certify Completion