Effort Certification

 RSP Effort Allocation and Certification Policy

 

INSTRUCTIONS FOR COMPLETING EFFORT CERTIFICATION REPORTS

 

STEP 1. 

Check that the heading items (Employee Name, Primary Organization, University ID, etc.) are correct.

STEP 2.

Check that the staff member contributed time and effort to the activities as identified by the account number(s) listed in the Direct Effort section.  If you do not recognize a sponsored activity, contact Michele Mullings-Shand at 3-6418.

A.     Section I. A. DIRECT EFFORT, should show the staff member's time and effort that was devoted to the grant or contract project listed by account number and paid by the sponsoring agency.

B.     Section II, OTHER INSTITUTIONAL ACTIVITIES should show the remaining percent of the staff member's time and effort devoted to "other" university activities (e.g. instruction, non-sponsored research, student service activities, general administrative activities).

Note:  The accounts listed under OTHER INSTITUTIONAL ACTIVITIES are usually accounts from which the employee is normally paid when not performing effort under sponsored activities.

STEP 3.

Check  that the percentages listed under the "P/R %" (payroll  %) columns are reasonable representations of the actual time and effort the staff member contributed to each "SPONSORED ACTIVITY" or "OTHER INSTITUTIONAL ACTIVITIES."  It is acceptable to consider the "average" effort for all months in the reporting period in lieu of the "actual" effort for each month listed.  If corrections are necessary, call Michele Mullings-Shand, as there may be a need for a revised PAF to be initiated.

Note:   Payments made to staff members as "special compensation" or  "miscellaneous payments" which were intended to be paid in addition to the staff member's regular salary should not be considered when verifying P/R %.

STEP 4. 

The staff member and an appropriate Supervisory Official (one who is able to verify the actual distribution of effort devoted by the staff member to all sponsored and other institutional activities) should sign the certification statement in the lower right hand corner of the form.  If a staff member is no longer employed by the University, the Supervisory Official should state this in the "Notes:" section.

STEP 5. 

Supervisory Officials should return the certified Effort Certification Report forms to the Department Head who will forward them to the Associate Grants and Contracts Administrator, campus zip 0394.

 


 

 RSP Effort and Certification Policy

Effective Date:  April 1, 2014

Purpose:

This policy outlines the University of Northern Iowa's obligations for allocating and certifying effort on sponsored programs as set forth by the Office of Management and Budget’s Circular A-21 (Cost Principles for Educational Institutions), commonly called OMB A-21. 

Policy Statement:

It is the policy of the University of Northern Iowa that all faculty and staff working on sponsored programs comply with all applicable regulations regarding the proposing, allocating and reporting of effort on a sponsored program(s).

This policy applies to all University of Northern Iowa administered sponsored grants, contracts, cooperative agreements, and memorandums of agreement, collectively referred to as “the sponsor” or a “sponsored program” here forward.

What is Effort?

Effort for non-hourly staff at UNI is reported in percentage.  Effort is the time a faculty or staff spends on any given task that he/she has been hired to perform for the university.  At UNI this set of professional duties generally includes instruction, research, administration, committee work, service work, and many duties not listed here.  Whether a faculty/staff spends 40 hours or 60 hours a week completing the duties, the sum of time spent completing the duties is 100% effort.  When UNI receives external funding the addition of effort from the sponsored project does not change the total percent effort (100%) available to work; the sponsored project effort should fit into the person’s 100% workload by having the faculty/staff be relieved of some of their existing duties or by increasing the Project Staff’s workload.  A sponsored program will not result in a temporary increase of compensation specifically to complete the work of the sponsored program.  

Acronyms and Definitions:

  • Principal Investigators/Project Directors (PI/PD):  The PI/PD is the lead faculty or staff working on a sponsored program.  The PI/PD is responsible for ensuring that all financial transactions directly support the scope of work and are within the parameters of the project budget.  The PI/PD is also responsible for all aspects of the project’s technical implementation, as well as ensuring that all technical reports are submitted according to the sponsor’s deadlines.  Also, the PI/PD is responsible for communicating with RSP if changes in scope of work occur, if budget revisions are needed, if an extension to the sponsored project deadline is needed, or any time a non-technical issue between the sponsor and UNI or the sponsored project staff occurs.
  • Project Staff:  For the purposes of this policy a “project staff” is any UNI faculty or staff who works on a sponsored program and certifies effort to that program at UNI.  Project Staff includes any staff that directly works on a sponsored project, including the PI/PD.  As defined above, the PI/PD is a Project Staff with project management responsibilities that go beyond those of other Project Staff.   
  • Personnel Action Form (PAF):  This form that allocates effort to the accounts from which the faculty/staff will be paid.  PAFs at UNI reflect the faculty/staff’s anticipated level of effort that will be allocated to each program within the period of time indicated on the PAF.  The effort allocations indicated on the PAF(s) are what faculty and staff certify during effort certification.
  • Effort Certification Report:  This form is created by staff at RSP and sent to the project staff’s Department Head.  It contains the percent of time allocated to each account and the base salary paid to the project staff by month during the reporting period.  The time and pay are based on the information from the UNI payroll office.  Effort Certification Reports are sent twice a year, once in the fall and once in the spring.  Effort certification is after-the-fact verification that the PAF effort allocation matches the actual effort tracked by the PI/PD.
  • Cost Share Sheet: Many sponsored programs require that UNI contribute a portion of the funds required to implement the overall program.  The portion contributed by UNI is referred to as “cost share”; the terms “match” or “matching funds” are often used interchangeably with cost share.  RSP documents and certifies a Project Staff’s cost shared effort to a sponsored program using the Cost Share Sheet.  Effort on behalf of UNI Project Staff is commonly used as cost share.

Effort Certification Responsibilities:

The Office of Research and Sponsored Programs (RSP): RSP is responsible for collecting and filing effort certification for all sponsored programs administered through RSP.  RSP is responsible for ensuring that UNI is in compliance with federal regulations related to charging effort to a sponsored program.  RSP is responsible for distributing Effort Certification Reports to the department head/unit director and collecting and filing the completed reports from these individuals.

Human Resources (HR) and Office of Business Operations (OBO):   HR and OBO are responsible for processing Personnel Action Forms (PAFs) and retaining effort distribution records.

Departmental PAF Preparers:  Working with the PI/PD and/or Project Staff, Departmental PAF Preparers are responsible for creating and routing the predicted or changed PAF for approval.  Departmental PAF Preparers are required to manually add the subject of the PAF to the PAF routing list every time the effort is created and/or changed on a PAF.

Project Staff:  Project Staff are responsible for working with the departmental PAF preparer and the PI/PD to create a PAF for themselves and for notifying the departmental PAF preparer if a change to the PAF needs to be made.  They are responsible for keeping track of their sponsored program effort, using a reasonable means of time tracking, and certifying the accuracy of their reported effort twice a year by reviewing, correcting if necessary, and signing the Effort Certification Report documents issued by RSP.  If applicable, the Project Staff must also co-certify the effort of any direct report Project Staff who certifies effort on a sponsored program. 

Principal Investigators/Project Directors (PI/PD): The PI/PD is responsible for creating accurate budgets during the sponsored program application phase and, once funded, the PI/PD is responsible for devoting the appropriate amount of effort to the sponsored program(s) during implementation.  The PI/PD is also responsible for working with departmental PAF preparer(s) to create a PAF for themselves and, if applicable, other project staff working on the sponsored program, that accurately anticipates effort for the sponsored program(s) and for notifying the departmental PAF preparer(s) if the anticipated effort on the PAF needs to be changed.  Finally, the PI/PD is responsible for keeping track of their sponsored program effort, using any reasonable means of time tracking, and certifying the accuracy of their reported effort twice a year by reviewing, correcting if necessary, and signing the Effort Certification Report documents issued by RSP.  PI/PD’s are also responsible for co-certifying any direct report co-PI/PDs or project staff. 

Project Staff Supervisors: The Project Staff’s supervisor is responsible for reviewing proposed effort to ensure it is reasonable in the context of the Project Staff’s existing workload and ensuring that the proposed effort will fit within the Project Staff’s 100% UNI effort load.  Once awarded, the Project Staff’s supervisor is responsible for co-certifying the RSP issued effort reports after the Project Staff has certified the effort.

Department Head/Unit Director:  the Department Head/Unit Director receives all Effort Certification Reports from the RSP office and is responsible for distributing the reports to all Project Staff within their department/Unit, collecting the signed certifications, and returning them to the RSP office by the date indicated by RSP.

Timeline for Effort Certification

Effort Certification Reports are issued twice per year, once in the fall and once in the spring.

  • Spring:  The spring-issued Effort Certification Report, issued in February or March, covers the fall semester for faculty, Academic Administrators and Graduate Assistants and July to December for P&S and Merit employees.
  • Fall:  The fall-issued Effort Certification Report, issued in October or November, is for certifying the spring semester and summer appointments for faculty, Academic Administrators and Graduate Assistants and January-June for P&S and Merit employees.

Allocation of Effort:

At any time Program Staff can review their current PAF effort allocation by logging onto UNI’s MyUniverse web application from the UNI homepage and navigating to the “Work at UNI” tab and then the “d-Business Resources” pagelet.  All current and historical PAFs are located at the “My Personnel Action Forms (PAF)” link. 

Preaward Effort Allocation:  Effort allocation begins when a Project Staff anticipates that a specific percentage of effort will be spent directly working on a sponsored project during the sponsored project proposal or contract negotiation process.  Working with a RSP Preaward staff member, other Project Staff, the Project Staff Supervisor, and others central to determining how much effort to propose, the Project Staff should fully consider how much effort the project will require and whether there is a need for a release of some existing duties or room to add the sponsored program duties to the Project Staff’s existing workload. 

Once the effort allocation to a sponsored program has been officially proposed UNI and the sponsor fully expect that the proposed effort will be allocated to the sponsored award and will not change.  When allocating effort during the proposal phase Program Staff are allowed to average their time over several months to account for likely fluctuations between what is predicted and what actually occurs during program implementation.  In some cases the average effort allocation may be proposed in a single percentage for an entire project period, however, during the implementation phase of the project the effort may vary from month to month, depending on the nature of the project.   

Postaward Effort Allocation:  Once a sponsored project is funded the proposed effort allocation should be used to create the PAF.  There are exceptions.  In some cases the project sponsor may offer fewer funds than requested, request a change in the scope of work, the project period may be less than anticipated, etc.  These may be reasons for changing the proposed effort allocation when creating the PAF.  However, unless a formal exception has been made, the proposed effort allocation should be used to determine the total effort over the project’s implementation period. 

Because effort allocation using the PAF is a predictive practice, the Program Staff should consider how much time during specific periods of the project implementation phase will be needed to complete the project and create the PAF accordingly.  The actual anticipated effort per month may or may not be the same as the averaged effort over the project’s implementation period.  For example, some projects may require a higher percent of effort during the spring and less during other times of the year.  This variable effort requirement should be reflected in the PAF and would result in needing to create at least two PAFs allocating two different levels of effort to the sponsored project.  Project Staff should allocate effort according to the actual anticipated effort so long as the average effort does not exceed the originally proposed and agreed upon effort allocation.     

When a Change in Effort Occurs:  As the project is implemented the actual effort needed to complete the project may be different from the predicted effort allocated on the PAF.  When a change occurs it is the Project Staff’s responsibility to inform the PI/PD (if applicable) and work with the PAF Preparer to change the effort allocation on the PAF.  When the change in effort is minimal, and the effort allocation change is predictive, the PAF adjustment can occur without involving the RSP office prior to making the change.  When effort changes significantly and/or the change is retroactive the Project Staff and PI/PD (if applicable) should contact the RSP office.  Significant changes in effort often require UNI to seek prior approval from the sponsor and may require a project budget revision.

When changes to effort allocation are retroactive the Program Staff should make sure that the PAF change is made within 90 days of when the need to change the effort allocation is first noticed and, very importantly, ensure that the retroactive effort allocation does not extend into a period when the effort has already been certified.  If a retroactive effort allocation is needed and the change will impact a period when effort has already been certified the Project Staff must contact the RSP office.  Changing incorrect effort allocations retroactively, even when the correction impacts previously certified effort, is always the correct course of action.   

Effort Certification:

The instructions for completing the Effort Certification Report are found at the top of this webpage.

Effort certification, as required by OMB Circular A-21, is the process of reviewing and verifying that the predicted effort allocation of the PAF and resulting payroll distribution is a correct reflection of the effort actually spent working on the sponsored project. The information that requires certification is found on the Effort Certification Report, which is provided to the Project Staff by the Department Head/Unit Director, who receives each Project Staff’s Effort Certification Report two times a year from RSP.  Each Program Staff must certify her/his own Effort Certification Report by signing the report.  The Project Staff Supervisor co-certifies all direct-report Project Staff-certified Effort Certification Reports.  The fully certified Effort Certification Report is collected by the Department Head/Unit Director and returned to RSP. When the Project Staff is reviewing the effort report, it is acceptable to average effort for all months in the effort reporting period in lieu of the actual effort for each month listed on the effort certification report. If corrections to the Effort Certification Report are necessary, the Project Staff should contact RSP and her/his Project Staff Supervisor.  Changes to the Effort Certification Report may result in the need for a revised PAF or have other implications for the sponsored project, such as triggering a budget revision.  Regardless of the implications to the PAF, project budget, etc. it is critical that the Project Staff identify and rectify an incorrect Effort Certification Report rather than certify the incorrect effort.      

NOTE: Payments made as special compensation or miscellaneous payments which were intended to be paid in addition to the faculty or staff member's regular salary should not be considered when certifying effort.  UNI’s Special Compensation Policy 4.16 can be found on UNI’s website.

Certified Effort
Once the effort certification process has been completed, including any changes that were made to the Effort Certification Report (if any), the effort is considered to be certified as correct.  A change to certified effort must be considered carefully.  Changes to certified effort are an institutional audit risk.  Significant fines and/or sanctions from the federal government can result if it is determined that effort was fraudulently certified or recertified.  Thus, once the effort certification process is completed and the effort is considered certified a significant level of justification must accompany a change in certified effort.  The reason is, obviously, because certified effort has already been reviewed and deemed correct.  However, making changes to certified effort is preferable to allowing incorrectly certified effort to remain “certified”.  If a Project Staff, or any other individual, has reason to believe that certified effort is incorrect, taking corrective measures is always the proper course of action and in doing so the institutional audit risk is reduced. 

Recertification of Effort:
Recertification of effort is not desirable but is necessary if an error occurred during the effort certification process.  A retroactive PAF would likely result and the effort certification process using a reissued Effort Certification Report for the previously, and erroneously, certified effort period would be required.  The original and incorrect Effort Certification Report, the recertified Effort Certification Report, and a RSP-approved justification would be filed and retained for audit purposes.   

Certification for People Who Leave UNI:
If a Project Staff does not certify effort prior to leaving the university, the Project Staff Supervisor or Department Head/Unit Director must certify the Project Staff’s effort.  If the Project Staff Supervisor and Department Head/Unit Director cannot accurately certify effort, the Department Head/Unit Director must identify a person who has suitable means of verifying that the work was performed, when, and at what level to certify the effort.