Effort Reporting Policy

Policy Date: April 2022
Revision: 7
Last Review: April 2022

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 mechanism used to provide assurance to federal or other external sponsors that payroll expenses charged or cost shared to sponsored projects are reasonable in relation to the work performed.

Background

As a recipient of federal funding, the University is required to comply with the standards for documentation of personnel expenses to federal awards, which are found in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (§200.430(h)8), frequently referred to as the Uniform Guidance. According to this regulation, while the University can initially charge payroll expenses 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 amounts charged to the federal award are accurate, allowable and properly allocated. The University applies this requirement to all sponsored project accounts, federal and non-federal.

General Policy

Effort on sponsored projects is reported as a percentage of total institutional effort during a reporting period. The certification process verifies that payroll expenses either directly charged or cost shared to a sponsored project are reasonable for the amount of effort spent on activities that benefited project's scope of work.

Who Must Comply

Effort directly charged or cost shared to sponsored projects by academic and administrative faculty, classified staff, postdoctoral fellows, graduate assistants and letters of appointment must be certified. Hourly employees who report time directly into Workday, such as undergraduate student employees, are exempt from the requirement to certify.

Policy Elements

Effort: Effort refers to an employee’s work on any institutional activity for which they are compensated. Effort on a sponsored project is reported as a percentage of total institutional effort.

Total Institutional Effort: All compensated effort performed by an employee during a specific effort reporting period. This includes work on sponsored and non-sponsored activities, work performed outside of normal work hours, and work performed off-campus. The total institutional effort will always equal 100% even if the employee has less than a 1.0 FTE appointment.

Reasonably Accurate: The federal government requires that payroll expenses charged to a project are consistent with an individual's actual effort in order to ensure that a sponsor is only charged for the amount of effort that directly benefited the project's scope of work. However, the federal government also 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.

An effort report is considered reasonably accurate if the reported effort deviates from actual effort by less than 5%. A payroll accounting adjustment is required if the amount of effort charged or cost shared to a sponsored project and actual effort deviates by more than 5% over the effort reporting period.

Certification: The attestation by an employee or proxy/designee that payroll expenses charged to sponsored projects as direct charges or cost share reasonably reflect the amount of work performed for the benefit of the project's scope of work during a specific 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. Both directly charged and cost shared effort must be certified during the effort reporting process.

Cost Shared Effort: Effort that is paid by the University or another non-sponsor source that benefits a sponsored project's scope of work. Mandatory, salary cap and voluntary committed cost share effort must be reported during the period in which the work was performed. (Please refer to the Institutional Sponsored Project Cost Sharing policy for more detailed information.)

Effort Reporting Period: The academic semester or non-contract period during which an employee performs effort. Effort reporting periods include fall (July through December contract period), spring (January through June contract period), winter/spring break (December, January and March non-contract periods) and summer (May through August non-contract periods).

Effort must be reported in the period in which it was worked: contract period effort must be reported on a contract period effort report, and "overload" effort must be reported on a non-contract period effort report. Departments should make every effort to pay for non-contract period effort prior to the generation of effort reports.

Institutional Activities: Institutional activities include all job duties or assignments for which an employee is compensated and that benefit the institution.

Institutional Base Salary (IBS): IBS is the Total Base Pay in Workday paid by the University for individuals holding faculty appointments, whether that individual's time is spent on research, instruction, administration or other activities. IBS assumes the employee is at 100% FTE and will work the entire fiscal year. The IBS employee start or end date may not coincide with the fiscal year start and end date. IBS excludes any income that an individual is permitted to earn outside of their institutional responsibilities (e.g., consulting payments).

Institutional Base Salary:

• Is a commitment by the institution regardless of the source of funds;
• Is not modified by furlough or temporary budget reductions;
• Excludes payment for secondary assignments for which an administrative stipend, overload or other supplemental pay is made; one-time payments; and extra compensation such as a housing allowance, cell phone stipend, relocation reimbursement, awards, etc

Roles and Responsibilities

Effort reporting is a federal compliance requirement. There are many individuals involved in this process, and each one has a role in ensuring that effort certifications are accurate and completed on time.

Principal Investigator (PI): It is the PI's responsibility to verify that all payroll expenses directly charged or cost shared to their sponsored projects are accurate, allowable and properly allocated. PI responsibilities are as follows:

• Communicate payroll allocations for employees to department administration.
• Review posted payroll expenses on a monthly basis to verify that each employee is being paid the appropriate amount from the sponsored project worktag or cost share worktag based upon 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.
• Ensure that effort directly charged or cost shared to their sponsored projects are accurate and completed on time.

Effort Certification Manager: The Effort Certification Manager (ECM) is responsible for providing oversight of the University's effort reporting program by creating and implementing effort reporting policies and procedures. The ECM generates effort reports, monitors their progress, and provides training on the effort reporting process and related policies and procedures.

Effort Certification Reviewer: Effort reports route first to an employee’s Supervisory Organization. Each Supervisory Organization is assigned one or more Effort Certification Reviewers (ECRs). ECRs are responsible for providing an administrative review of effort reports assigned to them prior to certification. ECR responsibilities include the following:

• Review effort reports for payroll distribution errors, cost shared effort, salary cap issues and other unique reporting requirements for various sponsors.
• Submit Payroll Accounting Adjustments (PAA) as needed.
• Route effort reports to other ECRs and PIs as needed.
• Communicate any questions or concerns to the ECM.
• Monitor the progress of effort reports so that they are certified on time.

When an employee has sponsored project effort in more than one department, an ECR should route the effort report to ECRs in other departments for additional administrative reviews. Effort reports may also be routed to PIs or supervisors for review prior to certification.

Certifier: An effort report is routed to a Certifier after the administrative review. The Certifier is ultimately responsible for the accuracy of the effort report. The Certifier must verify that the amount of payroll expenses directly charged or cost shared to a sponsored project are reasonable in relation to the amount of effort that was actually spent on the project. If the effort report is not accurate, the Certifier is responsible for communicating the error to the ECR and/or PI so that it can be corrected prior to certification.

Employees who work on sponsored projects are generally expected to certify their own effort reports. However, there may be instances where a supervisor or PI has a better understanding of how an employee spent their time on a sponsored project or an individual is no longer a University employee. In such circumstances, a PI, supervisor, or other person who has first-hand knowledge of how the employee spent their time during the reporting period may certify effort on behalf of the employee. In these situations, if an employee had more than one supervisor during the reporting period, the effort report should be routed to all supervisors for certification.

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

Effort reports should be certified within 28 days of the date they are initially generated. Failure to certify within 28 days will result in the following:

Late Notice: The ECR, Certifier and the PIs of all sponsored projects on the effort report will receive a late notice after the 28-day due date has passed. The late notice will inform the recipients that uncertified payroll expenses are unallowable on sponsored projects and will be removed from sponsored project worktag if not certified before effort reports become delinquent.

Delinquent Notice: Fourteen days after the late notice, the ECR, Certifier and the PIs of all sponsored projects on the effort report will receive a delinquent notice. At this time, the ECM will recommend to the associate vice president for research administration that all uncertified payroll expenses be moved from sponsored project worktags to non-sponsored worktags. If approved, the ECM will notify the PI and will work with the PI’s department to ensure that uncertified payroll expenses are removed from sponsored project worktags.

Note: Exceptions to the non-compliance policy will be made if a Payroll Accounting Adjustment must be delayed for budget setup or delayed funding reasons, or if there are verifiable extenuating circumstances. In these situations, effort reports may remain uncertified until the Payroll Accounting Adjustment posts in Workday or the extenuating circumstances have been resolved. ECRs must advise the effort certification manager of these situations.

Alternative to Traditional Effort Reporting

With the implementation of the Uniform Guidance, the University has the flexibility to create an alternative method of reviewing payroll expenses directly charged or cost shared to a sponsored project. Upon approval from the associate vice president of research administration, the University will allow an award-based detailed payroll expense report to replace the traditional effort report.

When the alternative method is utilized, it will be the PI’s responsibility to review the detailed payroll expense report and initiate any necessary adjustments. The final certified detailed payroll expense report will serve as documentation that payroll expenses directly charged or cost shared to the project were reviewed and that the expenses are accurate, allowable and properly allocated.

Employees whose payroll expenses have been certified by the PI on a detailed payroll expense report will not be required to certify their effort in the traditional effort reporting system. The detailed payroll expense report will serve as the certification that the payroll expenses directly charged or cost shared to the project accurately reflect the work that was performed.