Effort Certification & Reporting

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Definitions

Effort 

Effort is the time spent on any activity by an individual, expressed as a percentage of the individual’s total effort. It includes the time spent working on a sponsored project in which salary is directly charged. Total effort refers to all professional activity (instruction, research, administration, etc.) for which an individual is compensated by the University.

Effort Reporting

Effort Reporting is the process by which the University determines and documents the effort expended on sponsored projects during each reporting period.  The effort report is broken down by the proportion of effort devoted to sponsored and other non-sponsored activity.

Effort Certification

Effort Certification is the affirmation by the individual completing each effort report certification that the percentages of effort are accurate.

Rice's Obligation

Rice University is required to comply with the Office of Management and Budget Circular 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.  

All individuals who receive federal sponsored funding are required to comply with the sponsoring agency regulations regarding the proposing, charging, and reporting of effort on sponsored awards 

Understanding the Concept

Universities must assure federal (and most other granting agencies) that the assignment of time and associated salary and fringe benefit costs for the projects they sponsor is fair, consistent, and timely. Faculty and staff must collaborate effectively to ensure effort reporting is accurate and certified.

When a funder has sponsored specific research, their legitimate and reasonable expectation is that the individuals whose salary costs are being met by their funding are actually carrying out effort (work) in support of furthering the project goals they've agreed to sponsor in a direct and clear way. For the university to charge costs inaccurately or inappropriately is a major problem that can lead to major consequences. Effort reporting inaccuracy can ultimately lead to a university falling foul of the False Claims Act, leading to a judgment against the university and potentially an expensive settlement. 

After-the-fact Effort Reporting System

There is an element of grace baked into the effort reporting and certification process where it is understood that it is very difficult or impossible to be precise in all cases regarding effort. The federal government (and by extension Rice) applies a 'within 5%' window of acceptable uncertainty when confirming system data 'after the fact'. 

The Uniform Guidance Subpart E §200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. Rice's reporting system is used to certify that salaries charged to sponsored awards, including committed cost share, are reasonable and consistent with the work performed. 

Effort reporting applies to all professorial, professional, clerical and technical staff. The reports are prepared every six months on the following schedule:

Jan-Jun
July-Dec

Project Manager Obligation

The Project Manager for an Award fulfills a pre-certification role in the effort certification process. In order to be able to fulfill this role, the Project Manager should be confident about the following for the effort certification period in question

• They know the nature of the ongoing project, whose effort is allocated to the project in order to further the objectives of the project, and what the intentions were in terms of allocable effort during this period for each individual.

• The alignment of this understanding should be maintained using a clear record of how staff time was distributed during this period. This record should be shared with the Award PI, the corresponding Project Co-I, or dedicated staff or post docs (in the case of large or programmatic awards where this level of direction exists) during preceding periodic meetings or communications (taking place at minimum quarterly) thereby allowing corrective feedback to have been sought and given as needed.

• Deviations from, or alterations to, prior plans should thus be discussed and ideally apparent to the Project Manager before they carry out their twice-yearly 'pre-review'. 

• The project manager, if different from the research administrator, (or the corresponding HCM initiator) will need to work with associated Research Administrator/HCM initiators to make necessary amendments to salary charged via labor redistributions.

• Once necessary amendments have been made, the Project Manager should press the 'pre-certify' button, thereby indicating to the Award PI that they are satisfied with the data for the period being accurate to within 5% and that the PI can now evaluate the record and certify each individual within it.

Research Administrator Obligation

The Research Administrator (who may also be the Project Manager in any given case, but equally may not be), must collaborate with the Project Manager to 

• Process corrective Labor Distributions to make the effort levels indicated in the ECC system match the actual effort carried out during the period. 

• Keep the Project Manager updated on what they are doing as their corrections once submitted will (often after several days of processing and system data updates) propagate through to the ECC system for action. 

Faculty Obligation

Co-PIs at Rice who may be responsible for the management of a project budget within a multi-project award do not certify the effort on that project.

The responsibility for certifying all projects within an Award lies with the Award PI .

The Award PI becomes able to certify effort on all projects within their awards following the completion of a 'pre-review' by the Award's Project Manager. 

Assuming no further amendments or corrections to the effort stated within the period being reviewed are instructed retrospectively via labor distribution at a future date, the Award PI carrying out this certification is the necessary final step in completing the effort certification obligations for a given six-month period relative to each project within their award. 

Competing Pressures in Effort Reporting and Certification

Effort levels might be assigned via labor distribution at the outset by an administrator based on the information stated in the proposal (the Budget and Budget Justification). The actual situation might turn out to be different, with effort from an individual needing to be reported against a different project for the reporting period in question. By the time an effort report makes it to the faculty for certification, it could potentially be the first time that they see the effort data and it may be divergent with the reality of who has been doing what research over the period, making the report they are looking at incorrect and uncertifiable. 

The faculty and the research administrator need to periodically communicate about who is currently charged to each of their projects, who is encumbered to be charged in the future, and if there are any updates or changes to the proposed schedule of research effort that need to be taken into account and acted upon via labor distribution instructions. The proposal budget and justification are only a plan and plans do not always proceed exactly as intended. 

Faculty and staff who do not understand the need for the reporting (and the consequence for non-compliance), are perhaps more likely to incorrectly assume that the needs for accurate attention and compliance are less important than they are.  Faculty are ultimately responsible for their 'certification' representations in the ECC system which means that Faculty are responsible for knowing what is happening on their projects, and whether the effort representations to them need to be corrected? 

Research Administrators and Project Managers must take responsibility in all possible ways to ensure their actions on behalf of the project are accurate and this includes clear communication and interaction with faculty. However, ultimately faculty are responsible and it logically follows that a part of that faculty responsibility is to engage earnestly with attempts made by research administrator and project managers who will be carrying out actions on their behalf to enable the faculty to meet that responsibility. 

Communication and understanding is not optional in order for there to be accuracy in this process.

Institutional training on both the concepts and importance of effort certification as well as the tools, resources, and processes to follow is necessary. In addition to the information below. 

Additional Resources

• An outline of the process is communicated in STARS training

• RCA guidance on Effort Reporting is stated here https://controller.rice.edu/rca-effort-reporting 

• Rice Policy on Effort Reporting is stated here https://policy.rice.edu/304 

• Formal Effort Certification training is outlined here https://controller.rice.edu/rca-effort-certification-training 

• The log in page for the Effort Reporting and Certification tool is here  https://effortreporting.rice.edu/ 

• A job guide for the Effort Reporting tool that Rice uses to certify effort is found here https://effortreporting.rice.edu/ecc/content/help/CertificationProcess.pdf