Policy, Effort Certification for Government Grants

Title:  Effort Certification Policy for Government Grants
Effective Date: 5/25/11
Issuing Authority: Provost and Government and Foundation Relations
Last Updated: 2/11/14

As a recipient of federal funds, St. Olaf College must comply with the Office of Management and Budget (OMB) Circular A-21 (Cost Principles for Educational Institutions). Section J.10 requires certification of effort to document salary expenses charged directly or indirectly against federally sponsored projects. This process ensures that salaries and wages are properly expended and that actual effort is consistent with the originally anticipated (budgeted) effort. St. Olaf’s effort reporting policies and procedures are intended to meet this requirement.

Policy Statement:

  1. Effort reporting shall reasonably reflect the percentage distribution of effort expended by St. Olaf employees involved in federally funded grants, contracts, and cooperative agreements. These reports shall reasonably reflect the activity for which the employee is compensated.
  2. Each exempt employee whose time is committed to a federally sponsored project shall complete an effort report. Non-exempt employees whose time is committed to a federally sponsored project shall fill out a timesheet, which certifies their time worked on the federally sponsored project.  Committed cost sharing, either voluntary or mandatory, must be included in effort reports.
  3. St. Olaf uses an “after-the-fact effort” reporting system. This indicates that the distribution of salaries and wages will be supported by activity reports signed by the Principal Investigator (PI).
  4. The Business Office is responsible for the distribution, collection, and retention of all employee effort reports. Individually reported data will be made available only to authorized auditors.
  5. The Effort report must represent, in percentages totaling 100%, a reasonable estimate of an employee’s effort for the period being reported. Compensated effort includes all research, teaching, administration, service, and any other activity for which an individual received compensation from the college. Employees are encouraged to refresh their memories by consulting calendars, schedules, correspondence, journals or other contemporaneous records of time commitments.
  6. Note that 100% effort is defined as the effort expended to accomplish the full set of activities encompassed by St. Olaf College appointments regardless of the number of hours expended on those activities. 100% effort is not defined as a set number of hours or days per week. It does not depend on FTE status.
  7. Effort and payroll distributions are NOT the same. The effort reporting process is a method for confirming salary charges made to all sponsored awards. Payroll distributions are estimates of how effort is anticipated to be expended.
  8. St. Olaf follows the NSF guideline that states a faculty member should not be compensated in excess of 2/9 of the academic year salary for work during the summer. Nevertheless, PIs must still devote the full committed effort as proposed and awarded without regards to the salary reimbursement limitation.
  9. Federal grant pay is to be paid over the period that the services are performed.
  10. The federal government can impose severe penalties and funding disallowances as a result of missing, inaccurate, incomplete, or untimely effort reporting. St. Olaf expects that PIs will complete time and effort reports completely and in a timely manner.

Procedures:

  1. When a PI receives an award from an external sponsor she or he will prepare a projected distribution of effort for the expected duration of the grant in consultation with the GFR post-award grant coordinator. This will be based on the budget proposed to the sponsor. The grant coordinator will provide this projection with the grant paperwork and budget to the Business Office.
  2. Each exempt employee working on federally funded projects during the academic year will be required to report at the end of Fall Semester/Interim, no later than February 28; and at the end of Spring Semester, no later than June 30. Exempt employees working on such projects during the summer will report by September 30.
  3. The Business Office shall provide a blank effort report to each exempt employee working on a sponsored project(s) 15 days before a report is required.
  4. Each employee receiving this form shall complete the actual percentage of effort for the given time period.
  5. Verification: All employees must sign their own individual effort reports. In addition, the PI must review and verify all effort reports associated with a sponsored project using suitable means of verification that the reported work was performed. If the PI is the employee completing the effort report, an associate dean must verify the report. If the PI is an Associate Dean, the Dean must verify the effort report.
  6. PIs are required to return appropriately completed and signed effort reports to the Business Office by the due date.
  7. Any salary reallocations or adjustments resulting from time and effort reports will be made as determined between the grant coordinator and the Business Office.

Employee Effort Certification Form