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University of Kansas Effort Certification Policy

Policy
Purpose: 

Fulfill University of Kansas effort certification requirements, in accord with 2 CFR Part 200 Uniform Guidance.

Applies to: 

All involved in sponsored research.

Campus: 
Lawrence
Edwards
Parsons
Juniper Gardens
Yoder
Topeka
Policy Statement: 

The University of Kansas requires all individuals who receive sponsored funding to comply with University policies and sponsoring agency regulations regarding the proposing, charging, and reporting effort on sponsored awards.  University faculty, staff, and graduate students are expected to charge their time to sponsored awards commensurate with the effort expended on all activities they perform.  Faculty and staff are required to certify their own effort, and PIs must certify the effort of their graduate students. ecrt will have two certification periods annually for all employees. Certifiers will have 60 calendar days to certify all assigned effort reports.  All employees involved in certifying effort must understand that penalties and funding disallowances could result from inaccurate, incomplete, or non-timely effort reporting.

Completion of Effort Certifications
Faculty and staff are required to review their own effort report, determine whether the percentages on the effort report reasonably reflect effort expended on sponsored and non-sponsored activities, and certify the effort totals on the effort report. PIs are required to do this same review, verification, and certification of the effort reports for graduate students appointed to their projects. Variances of up to 5% (and $100) for each line of funding listed are allowable and do not require an adjustment or recertification.  Variances over 5% (and $100) for each line must be corrected prior to final system processing of the effort report.  Faculty and staff must complete their effort report, and those of graduate students appointed to their projects, within 60 calendar days of the date they receive the e-mail that the certification period is open. The 30 calendar day issue resolution period, after the 60 day certification period, can be utilized by faculty and staff to address issues that arose during the certification period and to finalize certification of their effort reports; certifications that are completed during this issue resolution period will still be considered compliant.

Effort must be certified in a timely manner. Failure to certify during the certification period can result in the University suspending support for extramural activities on behalf of individuals who do not fulfill their responsibilities, including PIs who do not ensure the faculty and staff on their projects have certified. Specifically, the University will not:

  • Submit a grant proposal/application to sponsors for extramural projects if individuals who are in violation of the certification period deadline are listed as personnel in the application
  • Execute award agreements and establish accounts for projects that have individuals who are in violation of the certification period deadline are listed as personnel in the application

Responsibilities 
Effort reporting is a federal compliance requirement.  There are many individuals involved in this process and each one has a role in ensuring that certifications are accurate and completed on time.

Certifiers (Principal Investigators (PIs), Faculty, and Staff)

  • Understand federal requirements related to effort
  • Ensure the appropriateness and accuracy of all effort expended on sponsored projects
  • Review, initiate corrections when necessary, and electronically certify effort report(s) during 60 calendar day certification period
  • Communicate significant effort changes (over 5% and more than $100 per line threshold) to their effort coordinator(s)
  • Recertify effort report(s) in the 30 days recertification period, if effort changes over the threshold are made after a report has been certified
  • On federal projects, obtain prior approval if disengaged from the project for more than three consecutive months or if effort is reduced more than 25% from the budget awarded

     Additional PI Responsibilities

  • Certify effort statements of graduate students to accurately reflect their effort during effort period
  • Ensure faculty and staff appointed to their sponsored projects certify within the (re)certification period(s)

Effort Coordinators

  • Understand federal requirements related to effort
  • Monitor effort commitments, salary charges, and cost sharing on all applicable awards
  • Follow up with faculty, staff, and payroll coordinators to make adjustments to effort reports as necessary
  • Communicate to the central sponsored programs office any changes that require sponsor notification and/or approval
  • Review salary charges with faculty and staff, and post any salary distribution updates and/or corrections in a timely manner
  • Check effort certifications for accuracy during the review period
  • Monitor that effort certifications are completed within 60 calendar days after release to the certifier, and that recertifications are completed with 30 calendar days after release to the certifier

Office of Research

  • Develop and implement effort reporting policies and procedures.
  • Develop educational programs for all employees involved in the effort certification process.
  • Ensure that the effort system produces accurate effort statements in a timely manner.
  • Monitor system to ensure compliance.
  • Monitor the effort process for timely submission and report findings to departments.
Consequences: 

Failure to certify during the certification period can result in the University suspending support for extramural activities on behalf of individuals who do not fulfill their responsibilities, including PIs who do not ensure the faculty and staff on their projects have certified. Specifically, the University will not:

  • Submit a grant proposal/application to sponsors for extramural projects if individuals who are in violation of the certification period deadline are listed as personnel in the application
  • Execute award agreements and establish accounts for projects that have individuals who are in violation of the certification period deadline are listed as personnel in the application
Contact: 

Assistant Vice Chancellor
KU Office of Research
785-864-3289

Approved by: 
Vice Chancellor for Research
Approved on: 
Friday, July 1, 2016
Effective on: 
Friday, July 1, 2016
Review Cycle: 
Biennial (Every Two Years)
Background: 

As a recipient of federal funding, the University of Kansas is required to comply with 2 CFR 200 (Uniform Guidance).  KU applies Uniform Guidance requirements to all sponsored projects, regardless of the funding source.  Therefore, effort must be reported and certified for all individuals who receive salary support from a sponsored project or who expend effort on a sponsored project (even if they do not receive salary support from the sponsor).

Effort certification records must reasonably reflect the total activity for which the employee is compensated, encompassing both federally-assisted and all other compensated activities. The effort reports must account for 100% of an employee’s total effort, including research, teaching, administration, clinical activity, and any other activity for which an individual receives compensation of salary and wages from KU. Effort is expressed as a percentage distribution of total effort, and each percentage must reasonably agree with actual effort devoted to each activity in relation to the employee’s total effort. KU will utilize an electronic effort certification system, ecrt®, to certify that effort is a reasonable assessment of how time was expended, and that the effort allocation is accurate, allowable, and properly allocated.

Definitions: 

Effort is the amount of time spent on any activity expressed as a percentage of total institutional activities for which an individual is compensated by the university.

Please note that under federal regulations, effort for salaried employees (those who have exempt status) is not calculated based on a 40-hour work week, but rather effort is based on the employee’s total hours actually spent on work within the scope of his or her employment. For example, if an individual averages 60 hours per week during the reporting period and spends an average of 15 hours on a sponsored project, that represents 25% effort. The other 45 hours, allocated to other institutional activities, represents 75% effort. Effort will always equal 100%.

Committed Effort is the amount of effort proposed in a proposal or other project application that is accepted by a sponsor, regardless of whether salary is requested in support of the effort.

Cost Sharing is the commitment of institutional resources contained in the proposal/application and resulting award, which is quantifiable and must be accounted for and reported to the sponsor. This policy only refers to effort of employees and does not cover every aspect of cost share (i.e., third party or non-payroll expenses).

Institutional Base Salary is the annual compensation paid by the University of Kansas for an employee's appointment, whether that individual's time is spent on research, instruction, administration, or service.

Effort Certification is a means of confirming that all of the effort committed to a project, whether paid on the sponsored award account or expended in support of a project as cost share, has been performed, charged, and documented appropriately.

Recertification is the certifying of effort that was previously certified, but changed due to the processing of a Retroactive Fund Adjustment (RFA) or budget transfer.

Effort Picture is a snapshot of the entire effort reflected over the reporting period for the individual employee.

Responsible Official is determined on a case by case basis by the department or unit in consultation with the Principal Investigator. The Responsible Official may be the PI, Co-PI, or other individual who is knowledgeable of the work performed by the individual.

Reporting period is the actual dates in which the employee worked; this is the period in which we are looking to confirm the employee’s effort.

Certifier is the individual that must review and certify their effort report/statement. For KU, this includes all faculty and staff who were appointed to a sponsored project during the reporting period.

Effort Coordinator is the individual at the Shared Service Center or Research Center/Institute who reviewed the effort reports/statements for their unit(s) during pre-review, assists certifiers during certification period, and are responsible for ensuring certification compliance.

Primary Effort Coordinator is the effort coordinator that is listed on the effort report/statement, is the primary contact for certifiers, and received effort tasks for processing.

Keywords: 
Effort certification, effort reporting, sponsored projects, research administration
Review, Approval & Change History: 

08/22/2016: Updated to reflect new process and policy in relation to electronic effort certification.

07/05/2016: Updated to remove gendered pronouns.

03/26/2015: Technical edits to Background section.

03/19/2015: Updated policy statement to reflect effort certification cycles in accordance with federal Uniform Guidance; updated background and related other sections to link to OMB Uniform Guidance Title 2 of the Code of Federal Regulations (2 CFR 200).

06/16/2014: Updated 'Office of Research' to reflect accurate title; selected 'Lawrence' for required Campus field; minor formatting updates

07/22/2013: Updated Contact Information

Research and Sponsored Projects Category: 
Research and Sponsored Projects

Moderation History

Updated: August 23, 2016 - 16:00

Log message: Edited by j372a558@ku.edu.

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