Fayetteville Policies and Procedures 404.3

Effort Certification

Scope

This policy sets forth requirements for managing effort expended on sponsored programs administered by the University in compliance with federal regulation as defined by the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards found in 2 CFR 200.430 (referred to here as the Uniform Guidance). It applies to all individuals whose salaries are charged to sponsored programs, in whole or in part, and to all individuals involved in reviewing and certifying the effort of other individuals.

Purpose

The University receives significant funding for sponsored programs from the federal government and other external sources. The Uniform Guidance requires sponsored program recipients to maintain a system of internal controls that includes after-the-fact review of payroll charges made to awards. 2 CFR § 200.430(i)(1)(viii)(c). All necessary adjustments must be made such that the final amount charged to the sponsored program is accurate, allowable, and properly allocated. An after-the-fact review of payroll charges for sponsored programs is achieved by the effort certification process. Effort certifications are also required of payroll that is distributed on federal formula funds (federal appropriations by USDA).

Non-compliance with these requirements could result in the disallowance of payroll charges to sponsored programs. Penalties resulting from audits for noncompliance may include funding disallowances and significant financial penalties for the University.

Definitions

Effort is the time spent on any activity by an individual and is expressed as a percentage of the individual’s Institutional Base Salary (IBS). One hundred percent (100%) effort is the total time spent on University work within the scope of an individual’s academic appointment period (9 or 12 months), regardless of how many or how few hours the individual has worked in the reporting period. The total effort reported for an individual will always equal 100%, even if the individual is not a full-time employee. Total academic period effort includes an individual’s sponsored programs and non-sponsored activities that are funded by the University including work performed outside of normal work hours and work performed off-campus.

Institutional Base Salary (IBS) is annual compensation paid by the University for an employee’s appointment (9 or 12 months), whether that individual’s time is spent on research, teaching, and/or other activities. IBS does not include bonuses, one-time payments, or incentive pay. Additionally, IBS does not include payments directly to individuals from other organizations or income that individuals are permitted to earn outside of their University responsibilities, such as consulting. IBS must be used as the base salary on all proposals unless there is a statutory limit on compensation (e.g., NIH cap).

Effort Certification is affirmation by the individual with direct knowledge or a suitable means of verification that the work was performed and that the salaries charged to sponsored programs as direct charges or cost sharing reasonably reflect the effort expended and work performed during the period of work performed/reporting period.

Effort Certification Statement is an electronic document in Workday certified by the PI/faculty or proxy/designee that the salaries charged to sponsored projects as direct charges or cost sharing reasonably reflect the effort expended and work performed during the period of work performed/reporting period. Effort Certification Statements contain data indicating the percentages of an individual’s University Institutional Base Salary that were allocated to sponsored program accounts and other University activities.Effort Certifier is the individual who provides the Effort Certification.

Effort Manager is the individual within the Office of Sponsored Programs (OSP) who initiates and monitors the effort certification process.

Effort Reviewer is the individual who reviews the Effort Certification Statements for sponsored programs assigned to their department. Effort Reviewers are assigned by the relevant department administrator’s lead and have a working knowledge of costing allocations, payroll accounting adjustments, cost principles and the effort certification process.

Committed Effort is the amount or percentage of time an individual has communicated to the sponsor that they will work on a specific sponsored project over a specified period of time. Commitments are made in the award proposal and may be documented by the sponsor in award documents.

Cost Sharing means program costs that are not covered by the sponsor. Cost sharing of effort is the provision of faculty and/or staff time and related fringe benefits that were committed and provided in support of a sponsored program but are paid for by other sources of funding (for example, by a University department, college, or central administration). Cost-shared effort in excess of the commitment made in the proposal does not have to be identified or certified.

Who Must Comply

All individuals involved with the administration and conduct of sponsored program activities, including central and departmental sponsored program administrators, principal investigators, and other research personnel must comply with this policy.

Adherence to this policy is required for all effort related to sponsored programs and the committed cost sharing. It is the responsibility of:

The Effort Manager to:

Determine which reporting periods need to be initiated and when initiation will occur;
Initiate Workday Effort Certification Statements for all departments;
Notify Effort Reviewers and Effort Certifiers via e-mail when Effort Certification Statements are ready for the certification process;
Monitor overall Effort Certification Statement completion for the University;
Perform reviews to ensure data integrity;
Provide support to the certification process; and
Escalate outstanding Effort Certification Statements, as appropriate.

The Effort Certifier to:

Understand the University’s policies/procedures and complete required training;
Be aware of the individual’s level of committed effort to sponsored programs;
Review salary charges on sponsored programs on a routine basis with Effort Reviewers;
Ensure that changes to Effort Certification Statements are communicated to the Effort Reviewer;
Ensure that any effort changes requiring sponsor prior approval to committed effort are appropriately communicated to OSP;
Review the Effort Certification Statement to ensure the percentages correctly represent the individual’s effort based on salary charged to the project and the commitments made to the sponsor;
Communicate any significant changes in level of sponsored programs effort to their Effort Reviewers; and
Certify Effort Certification Statements in accordance with the due dates established by the University.

The Effort Reviewer to

Understand the University’s policies/procedures and complete required training;
Facilitate a timely and efficient process for those individuals required to certify effort;
Review Effort Certification Statements and make appropriate adjustments;
Understand the sponsored program accounts included on the Effort Certification Statements assigned to them for review, including but not limited to proposal budgets, effort commitments, and the terms and conditions of each sponsored program as well as sponsor handbooks, policies, and guidance;
Provide assistance to Effort Certifiers with the use of Workday and the effort certification process;
Ensure that Effort Certification Statements are reviewed and properly escalated for timely certification in accordance with the due dates established by the University; and Monitor the processing of payroll accounting adjustments resulting from the effort certification process.

The Department Chair/Division Head to:

Ensure compliance with the Effort Certification Policy;
Oversee effective processes in the department to assist with compliance with the Effort Certification polices and associated procedures; and
Take corrective action when notified of outstanding Effort Certification Statements.

Training Requirements

One time training is required for Effort Certifiers and highly recommended for,Effort Reviewers and Effort Managers. Effort Certifiers should complete training before they certify any Effort Certification Statements. Please see the HR Calendar or contact Research Accounting for more information about upcoming “Effort Certification Training.”

Certification Process

The University uses the Effort Certification Statements in Workday as its method of documenting individual effort performed on sponsored programs.

Effort Certification Statements will be initiated in Workday by the Effort Manager on a quarterly basis.

Upon initiation, Effort Certification Statements will route to the Effort Reviewer(s)’ Workday inbox for an administrative review, and submission to the Effort Certifier to certify and complete the effort certification process.

Faculty and salaried staff are required to certify their own Effort Certification Statements.

Faculty and salaried staff assigned as Principal Investigators will receive the Effort Certification Statements for all graduate students and hourly workers engaged on the sponsored program. The Principal Investigator who directly supervises the graduate student and/or hourly worker must certify the Effort Certification Statement in Workday.

When certifying an Effort Certification Statement, Effort Certifiers are expected to review the salary percentages and determine whether those percentages reasonably correspond to the percentages of the individual’s actual effort on each sponsored program or other activity. If the percentages of a salary distribution accurately reflect a reasonable estimate of the actual effort expended within a five percentage point variance, then the Effort Certifier should certify the Effort Certification Statement. If the percentages of a salary distribution do not reflect a reasonable estimate of the actual effort expended within five percentage point variance for an effort period, then the Effort Certification Statement must not be certified. The Effort Certifier must send back the Effort Certification Statement to the Effort Reviewer to correct Once the correction is complete, the Effort Reviewer should submit the Effort Certification Statement to the Effort Certifier to certify.

When certifying the effort report, how the individual’s effort was expended for the reported effort period is the criterion to utilize. Factors such as availability of funds should not influence the certification of the Effort Certification Statement. An individual’s total effort for an effort period will always equal 100%.

As most faculty members are engaged in teaching, administrative, and other duties, in addition to their work on sponsored programs, the total effort and salary for a faculty member should not be 100% committed to sponsored research, except under special circumstances that demonstrate otherwise.

Effort should be certified at the time the Effort Certification Statement is available to the responsible certifying individual unless that individual determines that the salary distribution is incorrect and should not be certified. Responsible persons are requested to complete Effort Certification Statements within thirty (30) days after the initiation date. Any Effort Certification Statement that is not completed within 60 days is considered late.

The Effort Manager will monitor and send notifications of outstanding Effort Certification Statements based on the following time frames.

Time Frame	Reminder e-mail sent to
30 days after first notification	Individual
60 days after first notification	Department Chair/Director, Effort Reviewer, and the Dean's Office
90 days after first notification	Same as above and the Vice Chancellor for Research and Innovation

The Vice Chancellor for Research and Innovation will determine the next steps if the effort remains uncertified after the above notifications.

A lack of a credible after-the-fact review may result in audit findings, fines, or disallowance of payroll expense on sponsored programs. Therefore, it is critically important to ascertain the reasonable correctness of the effort prior to certification.

Special Conditions

Summer Effort

Nine-month appointed faculty members are permitted to expend up to an additional three months of summer effort on sponsored programs, subject to sponsor policies, department chair approval, and the availability of funding.

The combination of summer teaching and summer research for a month cannot exceed 1/9 of the previous academic year salary (or 1/3 salary if they work all summer). If a nine-month appointed faculty member has administrative or responsibilities or other periods not involving research responsibility (e.g., vacations) during the summer period, then they are precluded from claiming 100% effort on sponsored programs during the relevant period.

Cost Share

Mandatory cost sharing needs to be reflected on the Effort Certifications to properly report full effort expended on the program.

See the “Cost Sharing Policy” and Frequently Asked Questions document for additional information and requirements about Cost Sharing.

Salary Reallocations and Recertifications

Salary reallocations made as a result of the effort certification process must be made in accordance with University policies and procedures on salary reallocations and cost transfers.

Once certification of effort has been completed, only in certain rare circumstances will subsequent salary adjustments be permitted.

Designees

All faculty and salaried staff are required to certify. In certain circumstances, they can delegate this responsibility to another individual with first-hand knowledge of their sponsored program(s). The Effort Certifier must attest that the salaries charged and effort expended reasonably reflect work performed on the project and that they have sufficient technical knowledge and/or are in a position that provides for suitable means of verification that the work was performed.

Requests for delegation are made by completing the Request for Delegation of Authority for Effort Certification. The completed and signed forms are sent to the Dean of the individual whose efforts are being certified, and the Assistant Vice Chancellor for Research and Innovation, Senior Director of OSP for review and approval.

Principal Investigators Leaving the University

Prior to a Principal Investigator’s permanent departure from the University, they are required to complete the requisite Effort Certification Statements for themselves and GAs/hourly workers for which they are directly responsible.

If the Principal Investigator is transferring awards to another institution, Effort Certification Statements should be submitted prior to the University’s relinquishment or transfer of the sponsor program(s).

The Principal Investigator should certify all outstanding Statements in Workday prior to their departure.

Additional Resources

Please contact Effort Manager at effort@uark.edu. Also see the Research Accounting website (https://financial-affairs.uark.edu/research.asp) for additional information, such as Frequently Asked Questions and the Effort Certification Training PowerPoint.

Revised August 22, 2022
Reformatted for Web May 6, 2014
Revised July 22, 2014
Revised March 27, 2013
November 2011