Effort Reporting Policy

Policy Date: April 2017     Revision: 4     Last Review: March 2017

Purpose 

The purpose of this document is to provide guidance to ensure that all persons responsible for effort reporting at the University of Nevada, Reno (University) have the necessary information to submit accurate and timely reports.  

Definition   

Effort reporting, also known as effort certification, is the process of confirming that an employee's payroll distribution reflects a reasonable estimate of the employee's actual effort on all institutional activities.  

Faculty, staff and students working on sponsored projects are required to report effort on sponsored projects on a systematic and reasonable allocation basis. The University uses the Effort Reporting System (ERS), a web based application, for the certification of effort. Principal Investigators (PIs) are responsible for assuring that all payroll expenses charged to their sponsored project are certified. Administrative units shall provide assistance to investigators in order to enable the timely and accurate submission of effort reports. Additionally, administrative units shall ensure that employees receive the appropriate training for their specific role in the ERS.  

Background  

The standards for documentation of personnel expenses to federal awards are found in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (§200.430(h)8). According to this regulation, while the University can initially charge salaries to sponsored project accounts based on budget estimates, it must have internal controls to review the interim charges and make all necessary adjustments so that the final amount charged to the federal award is accurate, allowable and properly allocated. The mechanism the University uses for distributing salaries based on estimates of activity to be performed on sponsored project and other institutional accounts is the Payroll Action Form (PAF). Because the PAF is reliant on estimates of an individual's planned activities in the future, the regulations require an after-the-fact review to determine whether the estimated plan did or did not occur and that the employee met his or her commitment of effort on the project.   

Policy Elements 

Effort: Effort is work on institutional activities for which an employee is compensated by the institution.    

Accuracy: The federal government recognizes that teaching, research, service and administration are intermingled in the daily activities of personnel. Thus, personnel working on sponsored projects are not expected to precisely report how they spend their time; instead, a reasonable estimate over a specified period of time based on a percentage of effort is acceptable.     

Nonetheless, the federal government requires that salary charges are consistent with an individual's effort in order to ensure that a sponsor is only charged for the amount of effort that directly benefited the scope of work identified for that particular sponsor. A payroll cost transfer is required if the difference between what was paid and actual effort was more than 5% of an employee's salary over the effort reporting period.  

Committed Effort: The amount of effort proposed in a sponsored project proposal or other project application that is accepted by a sponsor. It is the policy of the University that committed effort is either directly charged to the sponsor or is reported as cost share.    

Cost Shared Effort: Mandatory, salary cap and voluntary committed cost share effort must be reported in the ERS during the reporting period in which the work was performed. The ERS only generates reports for employees who were paid from sponsored project accounts during the reporting period. Additional reports can be created for non-sponsored funded personnel who need to report cost shared effort by making a request to the research compliance program manager in Sponsored Projects.  

Effort Reporting Period: Effort reports are generated for employees in reporting periods based on the type of employee contract. Classified employees report effort on a monthly basis. Salaried employees report on academic semesters. "A" contract faculty report twice per year. "B" contract faculty have two additional reporting periods: one for work performed during the non-contract days in December, January and spring break and a second reporting period for work performed during the non-contract days in May, June, July and August.   

Effort must be reported in the period in which it occurs. Semester effort must be reported on a semester effort report. Overload effort must be earned and paid during non-contract reporting periods.  

Institutional Activities: Institutional activities include all job duties or assignments for which an employee is compensated and that benefit the institution. In the effort reporting process, faculty, staff and graduate students certify their effort on sponsored projects as a percentage of their total effort on all institutional activities.   

Institutional Base Salary (IBS): IBS is the annual compensation paid by the University for individuals holding faculty appointments, whether that individual's time is spent on research, instruction, administration or other activities. IBS excludes any income that an individual is permitted to earn outside of their institutional responsibilities (e.g., consulting payments). Consulting is addressed in the University Administrative Manual (UAM) section 2,690: Faculty Providing Consulting Services.  

Institutional Base Salary:

  • Is established by the institution in an annual letter of appointment, regardless of source of funds;  
  • Is guaranteed by the institution regardless of the source of funds;  
  • Excludes payment for secondary assignments such as department chair, center director or any other duties for which an administrative stipend or other supplemental pay is made;  
  • May not be increased or decreased as a result of replacing institutional salary funds with sponsored project funds; and 
  • Excludes merit, performance and bonus payments, honoraria, and extra compensation such as housing allowance, relocation reimbursement, etc.  

Payroll Cost Transfers 

Payroll cost transfers requested within two weeks of an upcoming effort reporting period should be accomplished by submitting a Request for Change of Payroll Charge (PR-45) form. Payroll cost transfers within two weeks of the generation of an effort report or after an effort report has been generated in ERS, must be accomplished through the cost transfer function in ERS, not on a PR-45. Reporting periods and report generation dates are listed on the Sponsored Projects Effort Reporting website.  

See the Payroll Cost Transfers policy for additional requirements for transferring costs to sponsored project accounts under the following circumstances:

  1. 90 or more days have passed since the cost posted,
  2. the cost is being transferred to an account that is closing within 45 days,
  3. the cost is being transferred to a project after its end date, or
  4. the cost is being transferred after effort certification.

Roles and Responsibilities 

Principal Investigator (PI): It is the PI's responsibility to verify that all personnel expenses charged to their sponsored project account are accurate, allowable and properly allocated. To meet this, PI responsibilities are as follows:    

  • Communicate payroll allocation for individual employees to department administration.   
  • Review posted payroll expenses each month to verify that each employee is being paid the appropriate amount from the sponsored project account based on the employee's effort.  
  • Ensure that employees are aware of how their assignments should be reflected on the effort report and that they promptly complete the effort certification.  

Sponsored Projects: Sponsored Projects is responsible for providing oversight of the University's ERS and designing and implementing the effort reporting policies and procedures. Sponsored Projects provides training on the ERS and the related policies and procedures.   

Pre-Reviewer: The pre-reviewer assigned in ERS is responsible for preparing effort reports for certification. Changes to the payroll data (via a cost transfer) may be necessary if there has been a change in an employee's effort from what was originally planned and directed by the PAF. The pre-review is also an opportunity to manage salary cap issues, NIH K-award efforts, cost shared effort or other unique reporting requirements for various sponsors. The effort form is not available for certification until the pre-review has been completed.  

If an employee has sponsored project payroll charges on accounts outside their home department, the department responsible for the project with the greatest percentage of sponsored project salary is responsible for pre-reviewing the effort report and conferring with the other department(s) to verify the accuracy of the reported effort.  

Certifier: Students and temporary hourly employees who submit timesheets to payroll prior to being paid are exempt from certifying effort in the ERS. All other employees who work on a sponsored project are expected to certify their own effort report. Employees must verify that their effort has been charged to the correct account and communicate issues or errors to the PI and/or pre-reviewer. There may be instances where a supervisor or PI has a better understanding of how an individual spent his or her time on a sponsored project. In such circumstances, a PI or supervisor who has first-hand knowledge of how the employee spent his or her time during the reporting period may certify effort on behalf of the employee. In the event that an employee has more than one supervisor, the supervisor with knowledge of the greatest portion of the employee's effort will be responsible to confer with the other supervisor(s) and mutually agree on the certifiable effort expended.   

Once the effort report has been certified, it is considered final. It may not be revised except under unusual circumstances. Certifiers are advised to ascertain that the report is accurate prior to certification. 

Non-Compliance 

All effort reports must be certified within 28 days of the date the pre-reviewers receive notification that the reports have been generated for that period. Failure to certify within 28 days will result in the following:    

Late Notice: The pre-reviewer, the certifier and the departmental coordinator responsible for the account will receive a late notice after the end of the reporting cycle. Daily email reminders will be sent to all of the above until the effort report is certified. 

Delinquent Notice: Fourteen days after the late notice, the pre-reviewer, the certifier, the departmental coordinator and the PI will receive a delinquent notice. At this time, the program manager for research compliance may recommend to the assistant vice president for research administration that the PI's accounts be put on administrative hold until all effort reporting has been completed.  

Note: Exceptions to the non-compliance policy will be made if a payroll cost transfer must be delayed for budget setup or delayed funding reasons. In these situations, effort reports may remain uncertified until the payroll cost transfer can be initiated in the ERS. Pre-reviewers must advise the program manager for research compliance of these situations.