Effort Certification

Amber Roberts

Institutional Effort Coordinator

Sponsored Projects Administration

The Basics

What? – What is effort certification?Why? –Why do we certify effort?When? –When do we certify?Who? –Who should be certifying?How? –How is effort certified?

What?

The Effort Certification system:Documents effort (the amount of personnel activity)

expended on federally sponsored projects Labor Distribution (payroll) information is pulled from

Oracle for each employee for creation of the effort statements. Fringe Benefits/OPE and Travel Reimbursements are not included in the calculation.

Certifying is the agreement that an employees payroll distribution and cost share (if applicable) is how they ACTUALLY spent their time on each federal project.

More What?

Certification is the assertion, by an employee or responsible official with suitable means of verification, that labor charges accurately reflect effort (activities) expended over the certification period

The “Statement”

When a person signs they are certifying to this statement:

“I certify that I have reasonable means of verifying the activities performed by the above mentioned employee and that the distribution for effort represents a reasonable estimate of the actual work performed by the employee during the period covered by this report.”

What is considered reasonable?Within 5% per line

Why?

OHSU’s Effort Certification system was developed in direct response to the Federal Office of Management and Budget (OMB) Circular A-21

A-21 addresses “principles for determining costs applicable to grants, contracts, and other agreements with educational institutions”

More Why?

A-21 aims to ensure that the Federal Government bears its fair share of total costs

A 21 states :Institutions must be able to document the

distribution of payroll charges using an acceptable method. OHSU uses after the fact Activity Records (J.10.c(2) in A21)

Failure to comply with A-21 can have very serious consequences

Even More Why- Committed Effort

What is the Committed Effort?It’s the effort commitment made at the time of

award for the Principal Investigator and Key Personnel.

Why is this important?We must honor our effort commitments. Most

federal sponsors consider a 25% or greater reduction an issue.

Auditors will compare committed effort in a grant application to actual effort on the certified Effort Certification Statements.

Even More Why- Committed Effort

OHSU follows NIH guidelineshttp://grants.nih.gov/grants/policy/nihgps_2001/part

_iia_5.htmGrantee must notify sponsor if PI or other Key

personnel reduce their committed effort by 25% or more

A letter must be generated by Principal Investigator detailing the new effort commitment requested. This is co-signed by the SPA Director.

Grantee can always increase effort above proposed

Faculty Committed Effort

Faculty cannot have 100% Effort on Sponsored Funding with the exception:If PI is receiving 100% salary support on sponsored

projects they need a signed statement on file from their departments Dean or Director specifying that they are 100% committed to research. This means the PI is does not have administrative, teaching, or clinical responsibilities and is solely working on their research projects.

When?

OHSU certifies effort semi-annuallyEffort periods end Jun 30 & Dec 31Effort periods close in February and August

Effort Process Timeline http://www.ohsu.edu/research/rda/spa/docs/effcerttl0110_0610.pdf

IEC Reminders

Institutional Effort Coordinator sends email reminders:That the effort period has ended (December 31st

and June 30th)Upcoming close and LD Lockout (In February and

August) of the effort period Statements are ‘in the mail’ and to check for

packetsUpcoming deadline for turning in statements (April

and October)

Who?

An employee is required to complete an Effort Certification Statement (ECS) if…Their activities are partially or totally devoted to a

sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity)

AND, pay is partially or totally paid from such an agreement, OR represents cost sharing

Who else?

Graduate Research Assistants receiving GRA support payments (object code 5198) need to certify their effort. HR has determined GRA’s to be “quasi” employees.

Research Training Fellows receiving stipend payments do not certify effort. They are not considered employees and are here strictly for a training experience.

Cost Sharing

Cost sharing is defined as the portion of the project or program costs not borne by the sponsor.The majority of Cost Sharing commitments are met

through effort/payroll expenseCost Shared Effort must be included on Effort

Certification Statements and certified.Cost Sharing must be from a non-federal account—

most likely a General Ledger Account.

How?

Oracle identifies individuals who are receiving effort related salary from federally sponsored and cost sharing accounts in the Payroll Module. Note: If you have someone who is receiving all of their

salary off of the GL, but have activities benefiting a project as cost sharing please be sure to contact the IEC at the close of the effort period.

Statements are generated showing the effort related percentages of payroll distribution the individual received on each account.

Effort Certification Statements Example

Print Date: Oregon Health and Science University Run:For the Effort Period: Jan08-Jun08 Effort Certification Statement Database: FISPRD 01/01/2008-06/01/2008

Employee#/ Name: 12345 Schultz, Charles Employee Coverage: 1-JAN-2008 To 30-JUN-2008Primary Organization: Mail Code:

Project # Award # Project Name Award Name % Payroll % C/S % C/S Total C/S Total EffortDistribution Committed Uncommitted

GL-Related Activities

0151-69999-11-5111-000-0000-000 UNIVERSITY GENERAL FUND 24.75%

OGA Related Activities

GRANT A AWARD A NIH Grant BBB interaction study 35.00%

GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28%

GRANT C AWARD C NIH Grant Stroke study 7.46%

GRANT D AWARD D AHA Grant Stroke study 8.29%

GRANT E AWARD E Univ of WA Stroke studies 20.22%

100.00% 0% 0% 0% 100%

I certify that I have reasonable means of verifying the activities performed by the above mentioned employee

and that the distribution of effort represents a reasonable estimate of the actual work performed by the Covered Individual Date

employee during the period covered by this report. Or

[_] Principal Investigator Responsible Official Date Relationship to covered Individual (please check one) [_] Supervisor

Responsible Official (Please print name)

Note on Suspense ActivitySuspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation.

Note on Cost SharingPlease enter the amount of cost sharing in each of the C/S fields. % C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing.

Note on Federal Salary CapIt is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then % Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the % C/S Committed column.

How?

More How?

What if cost sharing or corrections are needed?

Examples can also be found online at http://www.ohsu.edu/research/rda/spa/effortworkshop.shtml

Cost Sharing

If applicable, cost shared effort needs to be shown on a ECS. If a cost share companion account has been set up,

the account should be shown already on the statement.

If a companion account is not being used, cost sharing must be shown using a hand correction showing support from a non-federal sponsored account to the sponsored account.

Cost Sharing Hand Corrections

Print Date: Oregon Health and Science University Run:For the Effort Period: Jan08-Jun08 Effort Certification Statement Database: FISPRD 01/01/2008-06/01/2008

Employee#/ Name: 12345 Schultz, Charles Employee Coverage: 1-JAN-2008 To 30-JUN-2008Primary Organization: Mail Code:

Project # Award # Project Name Award Name % Payroll % C/S % C/S Total C/S Total EffortDistribution Committed Uncommitted

GL-Related Activities

0151-69999-11-5111-000-0000-000 UNIVERSITY GENERAL FUND 24.75% -10.00% -10.00% 14.75%OGA Related Activities

GRANT A AWARD A NIH Grant BBB interaction study 35.00% 10.00% 10.00% 45.00%GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% 4.28%GRANT C AWARD C NIH Grant Stroke study 7.46% 7.46%GRANT D AWARD D AHA Grant Stroke study 8.29% 8.29%GRANT E AWARD E Univ of WA Stroke studies 20.22% 20.22%

100.00% 0% 0% 0% 100%

I certify that I have reasonable means of verifying the activities performed by the above mentioned employee

and that the distribution of effort represents a reasonable estimate of the actual work performed by the Covered Individual Date

employee during the period covered by this report. Or

[_] Principal Investigator Responsible Official Date Relationship to covered Individual (please check one) [_] Supervisor

Responsible Official (Please print name)

Note on Suspense ActivitySuspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation.

Note on Cost SharingPlease enter the amount of cost sharing in each of the C/S fields. % C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing.

Note on Federal Salary CapIt is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then % Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the % C/S Committed column.

Salary Cap?

NIH prohibits employees from receiving a salary greater than the established cap ($199,700 for calendar year 2010) http://grants.nih.gov/grants/policy/salcap_summary.htm

Any amount above this cap must be considered Cost Sharing and charged to the appropriate non-federal account

For more information about the salary cap, please register for the Advanced Effort- Salary Cap PEP class

Change to the % of Payroll Distribution

The ECS is generated but the % of payroll needs to be changed.

1) Enter a change in Labor Distribution in Oracle to reflect the correct % of payroll

2) Do a hand correction to amend the ECS to mirror the Labor Distribution Change. Changes should be made to the left of the % payroll column

3) Complete a Labor Cost Transfer Form (LCTA Form)

http://www.ohsu.edu/research/rda/spa/docs/lcta.pdf

4)Submit all paperwork together to SPA

% of Payroll Distribution Hand Correction

Print Date: Oregon Health and Science University Run:For the Effort Period: Jan08-Jun08 Effort Certification Statement Database: FISPRD 01/01/2008-06/01/2008

Employee#/ Name: 12345 Schultz, Charles Employee Coverage: 1-JAN-2008 To 30-JUN-2008Primary Organization: Mail Code:

Project # Award # Project Name Award Name % Payroll % C/S % C/S Total C/S Total EffortDistribution Committed Uncommitted

GL-Related Activities

0151-69999-11-5111-000-0000-000 UNIVERSITY GENERAL FUND 24.75% 34.97% 24.75%OGA Related Activit ies

GRANT A AWARD A NIH Grant BBB interaction study 35.00% 35.00%GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% 4.28%GRANT C AWARD C NIH Grant Stroke study 7.46% 7.46%GRANT D AWARD D AHA Grant Stroke study 8.29% 8.29%GRANT E AWARD E Univ of WA Stroke studies 20.22% 10.00% 20.22%

100.00% 0% 0% 0% 100%

I certify that I have reasonable means of verifying the activities performed by the above mentioned employee Charles Schultz 9/13/2010and that the distribution of effort represents a reasonable estimate of the actual work performed by the Covered Individual Date

employee during the period covered by this report. Or

[_] Principal Investigator Responsible Official Date Relationship to covered Individual (please check one) [_] Supervisor

Responsible Official (Please print name)

Note on Suspense ActivitySuspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation.

Note on Cost SharingPlease enter the amount of cost sharing in each of the C/S fields. % C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing.

Note on Federal Salary CapIt is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then % Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the % C/S Committed column.

Suspense Activity Clearing

Suspense is where Labor Distributions go when there is not an account to place it in!

It starts with a 0051 Fund NumberAll Suspense must be cleared on ECS and in

LD before a statement can be accepted.

Suspense Corrections

The same protocol exists for the % of payroll change

1) Enter a change in Labor Distribution in Oracle to reflect the correct % of payroll

2) Do a hand correction to amend the ECS to mirror the Labor Distribution Change. Changes should be made to the left of the % payroll column

3) Complete a Labor Cost Transfer Form (LCTA Form)

http://www.ohsu.edu/research/rda/spa/docs/lcta.pdf

4)Submit all paperwork together to SPA

Suspense Hand Corrections

Print Date: Oregon Health and Science University Run:For the Effort Period: Jan08-Jun08 Effort Certification Statement Database: FISPRD 01/01/2008-06/01/2008

Employee#/ Name: 12345 Schultz, Charles Employee Coverage: 1-JAN-2008 To 30-JUN-2008Primary Organization: Mail Code:

Project # Award # Project Name Award Name % Payroll % C/S % C/S Total C/S Total EffortDistribution Committed Uncommitted

GL-Related Activities

0151-69999-11-5111-000-0000-000 UNIVERSITY GENERAL FUND 24.75% 24.75%0051-69999-11-5111-000-0000-000 SUSPENSE CLEARING ACTIVITY 0.00% 10.22% 0.00%OGA Related Activit ies

GRANT A AWARD A NIH Grant BBB interaction study 35.00% 35.00%GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% 4.28%GRANT C AWARD C NIH Grant Stroke study 7.46% 7.46%GRANT D AWARD D AHA Grant Stroke study 8.29% 8.29%GRANT E AWARD E Univ of WA Stroke studies 20.22% 10.00% 20.22%

100.00% 0% 0% 0% 100%

I certify that I have reasonable means of verifying the activities performed by the above mentioned employee Charles Schultz 9/13/2010and that the distribution of effort represents a reasonable estimate of the actual work performed by the Covered Individual Date

employee during the period covered by this report. Or

[_] Principal Investigator Responsible Official Date Relationship to covered Individual (please check one) [_] Supervisor

Responsible Official (Please print name)

Note on Suspense ActivitySuspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation.

Note on Cost SharingPlease enter the amount of cost sharing in each of the C/S fields. % C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing.

Note on Federal Salary CapIt is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then % Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the % C/S Committed column.

TBD Correction

The ECS is generated but an award is missing because an account is not yet set up in OGA.

1) Write in TBA for Grant Account Number

2)Show Effort in the Cost Sharing Column

3) Once OGA account is set up, LD can be changed and a LCTA form will be needed but you will not need to do an amended ECS.

TBD Hand CorrectionPrint Date: Oregon Health and Science University Run:For the Effort Period: JAN10-JUN10 1/1/10 To Effort Certification Statement Database: FISPRD 6/30/2010

Employee#/ Name: 12345 Schultz, Charles Employee Coverage: 1-JAN-2010 To 30-JUN-2010Primary Organization: Mail Code:

Project # Award # Project Name Award Name % Payroll % C/S % C/S Total C/S Total EffortDistribution Committed Uncommitted

GL-Related Activities

0151-69999-11-5111-000-0000-000 UNIVERSITY GENERAL FUND 25.00% -10% 15%

OGA Related Activities

GRANT1000A AWARD1000 NIH Grant BBB interaction study 25.00% 25%GRANT2000A AWARD2000 NSF Grant Alzheimer's Disease study 25.00% 25%GRANT3000A AWARD3000 AHA Grant Stroke study 25.00% 25%

TBD PI: Schultz, C NIH Grant Cardiac Study 10% 10%

100.00% 0% 0% 0% 100%

I certify that I have reasonable means of verifying the activities performed by the above mentioned employee Charles Schultz 8/30/2010and that the distribution of effort represents a reasonable estimate of the actual work performed by the Covered Individual Date

employee during the period covered by this report. Or

[_] Principal Investigator Responsible Official Date Relationship to covered Individual (please check one) [_] Supervisor

Responsible Official (Please print name)

Note on Suspense ActivitySuspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation.

Note on Cost SharingPlease enter the amount of cost sharing in each of the C/S fields. % C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing.

Note on Federal Salary CapIt is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then % Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the % C/S Committed column.

Additional Info & Things to Remember

Please document effort for each line in the far right column—this helps to explicitly show what the person’s effort is for each account

Effort must add up to 100% The date the statement was signed must be included If a responsible official signs (this must be someone

who has substantial knowledge of the individual’s effort), they must also include their printed name and check one of the relationship box options

Use pen (not pencil) to make corrections DO NOT use White out Total effort column needs to sum to 100%.

Cost sharing columns need to sum to zero SPA cannot amend these forms on your

behalf.

Additional Info & Things to Remember

A great tools to use before and after you get statements:Effort Certification Process Timeline (

http://www.ohsu.edu/research/rda/spa/docs/effcerttl0110_0610.pdf)

Effort Procedure (http://www.ohsu.edu/research/rda/spa/docs/effortcertproc.pdf)

OGADW Employee Effort Report Distribution by Period in Discoverer

If you aren’t sure about something, call the Institutional Effort Coordinator!

Additional Info & Things to Remember

There is approximately 30 days between the end and the close of the effort period. This time allows you to review and make any needed LD Changes. This helps reduce the need for payroll related hand corrections on the ECS.

DECs have approximately 35 business days between the time statements are distributed to the return deadline.

Outstanding statements are subject to the Notification Process

If DECs have a statement that will be late, please send in what has been certified before the deadline.

Additional Info & Things to Remember

Signature Reminder

It is generally inappropriate for a Departmental Effort Coordinator or a Department Chair to sign all of the Effort Certification Statements in the unit or department.

Let’s Review!

Let’s Review!

Let’s Review!

Let’s Review!

What Tools Are Available to with Effort Certification?Effort TimelineEffort ProcedureOGADW Employee Effort Report Distribution by

PeriodInstitutional Effort Coordinator (IEC)

Let’s Review!

Who needs an Effort Certification Statement?Anyone who’s effort/activity is partially or totally

devoted to a sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity)

AND, pay is partially or totally paid from such an agreement, OR represents cost sharing

Let’s Review!

When does OHSU Certify Effort?Twice Each Year (Jan1-June 30 & July 1-Dec 31)

How much time is provided to change Labor Distribution after the Effort Certification Period Ends (either June 30 or Dec 31)?30 business days

o Note: Keep an eye on the Effort Certification Process Timeline for deadline dates and when LCTA forms must be in for adjustments that do not auto approve.

Let’s Review!

How many days after SPA distribution date are the ECS form due back to SPA?35 business daysThe deadline date is listed on the Effort Certification

Process TimelineHow many notifications are sent for late Effort

Certification Statements?5, the last to the Dean or Director of the

Department

Let’s Review!

What is a reasonable estimate?+/- 5% per line

True or False? DECs must wait to submit all their ECS to SPA until they have all been signed!False!!! Please submit all certified statements

before the effort deadline

Let’s Review!

True or False? As a the Department Effort Coordinator, I truly do know what folks are up to in my department, and thus I can sign the ECS form.Most likely FALSE!!! Remember what the “statement”

says and what certifying means.

Let’s Review!

True or False? I can edit the Effort Statements with PencilFALSE. Pen please!

True or False? I can white out on Effort Statements.FALSE. The use of white out voids the effort

statement and a new one will be needed.

Let’s Review!

If you receive an ECS that needs a correction, what steps do you need to take?If payroll related, correct LD to match actual effort

performed (if cost sharing-no LD may be needed)Hand Correct Statement (using PEN) to reflect

Effort change and obtain appropriate signaturesComplete LCTA Form if LD change was madeSubmit all to SPA

One last thing!

What if you need to correct an already certified statement?AMENDING A STATEMENT ERODES THE

CREDIBILITY OF THE CERTIFIER AND THE STATEMENT SO PLEASE TRY TO ALWAYS AVOID THIS! BUT IF YOU MUST….There is a process for amending and recertifying effort statements. Submit an LD adjustment, LCTA form and an amended

ECS with hand corrections Complete a Effort Recertification Form located on SPA’s

website under Effort http://www.ohsu.edu/research/rda/forms.shtml#fm

Don’t forget the Effort Procedure is available online

The full text of OHSU’s Effort Certification Procedure is available on the SPA website: http://www.ohsu.edu/research/rda/spa/docs/effortcertproc.pdf

Questions?

If you think of something later you can contact the IEC at spaeffrt@ohsu.edu or at ext. 4-6984.