As a recipient of federal funding, UAF is required to comply with the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), as well as other federal requirements for certifying effort expended on sponsored awards. UAF requires all individuals who receive federal sponsored funding to comply with University policies and sponsoring agency regulations regarding the proposing, charging, and reporting of effort on those awards.
UAF receives significant funding for sponsored projects from federal and state governments, private foundations, organizations, and industry. There must be accurate effort planning and confirmation when these funds are expended for salaries and wages.
Uniform Guidance (2 CFR §200.430 – Compensation-personal services.) outlines the requirements for non-Federal entities to track and report payroll-related costs on Federal awards, usually referred to as “effort reporting” or “effort certification”. The primary requirement is that strong internal controls must exist for the reporting of salaries and wages to ensure that the charges “are accurate, allowable, and properly allocated” to the correct award. The reported effort must also be “be incorporated into the official records of the non-Federal entity,” which UAF handles via OnBase.
UAF faculty and staff are expected to charge their time to sponsored awards commensurate with the committed effort expended on all activities they perform. Payroll charges to sponsored awards and cost sharing recorded for faculty and staff serve as the initial data points for the University’s effort reporting system.
UAF’s practice is to utilize an after-the-fact effort reporting system to certify that salary either charged or cost shared to sponsored awards is reasonable and consistent with the work performed. The individual’s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended on each project is certified by a responsible person with suitable means of verification that the work was performed, generally the principal investigator, at the end of specified reporting periods. The effort certification should be a reasonable estimate of how time was expended. Uniform Guidance Section §200.430(c) states:
“It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs [institutes of higher, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”
Additional background information is available in Statewide's Accounting and Administrative Manual, Section D-04.
Who Must Comply?
All individuals involved with the administration and conduct of federally-sponsored award activities, including central and departmental sponsored project administrators, principal investigators, and other research personnel must comply with this policy.
Adherence to this policy is required for all effort related to federally-sponsored awards as well as any non-federal awards where the non-federal sponsor requires effort reporting.
- Non-Exempt Employees: certify every 2 weeks via their submitted timesheets
- Exempt Employees: certify with trimester Effort Certifcation Statements.
Principal Investigators (PI)/Faculty Members:
- Understand their own as well as their staff members’ (non-faculty personnel) levels of effort committed, charged and reported on all applicable awards.
- Review, initiate corrections if necessary, and electronically certify their individual their Trimester Project Effort Certification(s).
- Communicate significant effort changes to the department business administrators.
- If applicable, the PI must formally request via the OGCA Effort Certification email (email@example.com) that the certification responsibility be delegated to another individual who has sufficient technical knowledge and/or is in a position that provides for suitable means of verification that the work was performed.
- Review salary charges on awards on a monthly basis with grant manager and identify any effort-related changes and communicate with administrators to post corrections, if needed.
- Re-certify and electronically sign if effort changes are made after a statement has been certified.
Department/Unit Business offices:
- Monitor and review effort commitments, salary charges, and cost sharing on all applicable awards.
- Communicate to OGCA any changes that require sponsor notification and/or approval.
- Review salary charges with PI/faculty member and post any salary distribution updates and/or corrections in a timely manner.
- Check effort certifications for accuracy during the review period.
Office of Grants and Contracts Administration (OGCA):
- Communicate significant changes in effort to sponsors.
- Maintain UAF’s effort reporting policy and procedures.
- Provide effort reporting training, guidance on requirements, and oversee University-wide compliance with UAF’s Effort Reporting Policy.
- Manage the business/functional aspects of the electronic effort reporting system through OnBaseManage data uploads into OnBase.
- Staff the effort certification help email and respond to functional questions and issues.
Reporting and Certification Process
- There are three effort reporting periods at UAF each fiscal year (trimester basis): (1) fall, (2) spring, and (3) summer. Approximately one month prior to the end of a reporting period, OGCA will send out an email reminder that the period will be ending.
- Once the effort reporting period has ended (one month before the certification deadline), OGCA will send out a second email with approval to print out and complete needed effort certifications, instructions on completing the certifications, and information regarding available training.
- Two weeks before the certification deadline, OGCA will send out a third reminder that certifications are due, again with instructions.
- During the month window, from the end of the reporting period up to the certification deadline, OGCA receives the completed effort certifications via email (firstname.lastname@example.org) and complies them electronically. The certifications are verified for completeness, compliance, and signatures. The unit is notified if any certifications do not meet this review, corrections must be made, and the corrected certification(s) are sent back to OGCA.
- Fully complete, compliant, and signed certifications are batch uploaded into OnBase for auto-indexing. If auto-indexing is successful, the record can then be committed in OnBase. If auto-indexing fails, then the record must be manually indexed and committed in OnBase.
- Once the records are committed in OnBase, OGCA initiates a two-week verification phase, checking that all certifications are signed and dated within the appropriate reporting period and that a unit has submitted all required certifications. If a unit has any missing certifications, OGCA will send requests on a regular basis until all required certifications are received, indexed, and verified.
- Once all certifications have been received, indexed, and verified, OGCA will certify the effort reporting period as complete. This entire process is completed within 60 days from the certification deadline.
Note that total effort on Effort Certification Statements must equal 100% and cannot exceed 100%.
Effort Certification Schedule
Summer 2016 (May 15-August 20, 2016) R12-R18
- Printing of Certification Statements Available: After August 29, 2016
- Ad hoc training: August 22, 2016 contact email@example.com
- Certification Statement Deadline: September 29, 2016
Fall 2016 (August 21, 2016 - January 7, 2017) R19-R02
- Printing of Certification Statements Available: After January 16, 2017
- Ad hoc training: January 9, 2017 contact firstname.lastname@example.org
- Certification Statement Deadline: February 16, 2017
Spring 2017 (January 8 - May 13, 2017) R03-R11
- Printing of Certification Statements Available: After May 22, 2017
- Ad hoc training: May 15, 2017 contact email@example.com
- Certification Statement Deadline: June 22, 2017
Summer 2017 (May 14 - August 19, 2017) R12-R18
- Printing of Certification Statements Available: After August 28, 2017
- Ad hoc training: August 21, 2017 contact firstname.lastname@example.org
- Certification Statement Deadline: September 28, 2017
Fall 2017 (August 20, 2017 - January 6, 2018) R19-R02
- Printing of Certification Statements Available: After January 15, 2018
- Ad hoc training: January 8, 2018 contact email@example.com
- Certification Statement Deadline: February 19, 2018
Spring 2018 (January 7 - May 12, 2018) R03-R11
Failure to Comply
If Effort Certification Statements are not received by the internal deadline (see schedule above), notifications are escalated via unit fiscal officers, dean/directors, and the Vice Chancellor for Administrative Services.