Body
Title
Office of Sponsored Programs - 600.05 - Effort Reporting
Introduction
Purpose
The University must adhere to Federal, State, and University guidelines regarding financial oversight of sponsored projects to receive funding. The purpose of this Operating Standard is to ensure that effort statements completed in connection with University-sponsored projects are accurate, reasonably reflect the actual level of effort expended on a sponsored project, and comply with sponsor requirements.
As a condition of receiving sponsored awards, the University must assure sponsors that the effort expended on their sponsored projects justifies the salary charged to those projects. In addition, the University must assure sponsors that the commitment indicated (including mandatory and voluntary committed cost sharing) in the proposal and subsequent award is met in accordance with the sponsor’s terms and conditions. The University provides this assurance by requiring semi-annual effort statements for each individual whose salary is charged to one or more sponsored projects and/or cost-sharing accounts during the effort reporting period of performance. Completed effort statements indicate the percentage of the individual’s total University effort that is dedicated to the individual sponsored project(s) and other University activities, and requires a confirmation that the reported effort percentages are reasonable and accurate.
Each individual working on a sponsored project must be aware of their level of committed effort to sponsored projects, their ability to meet those commitments in light of any other University obligations they may have and to communicate any significant changes in the level of sponsored projects effort to their respective business office.
Scope of Applicability
This operating standard applies to all individuals within the University who manage sponsored projects, are involved in allocating compensation charges to sponsored projects, have committed effort (whether through salary support or cost share) to sponsored projects, or are responsible for confirming effort statements.
Policy Statement
The University is committed to ensuring that personnel compensation charges to sponsored projects are accurate and supported by confirmed effort statements submitted in a timely manner.
As a recipient of Federal funding, the University is required to comply with Uniform Guidance 2 CFR §200 Subpart F requirements for certifying time spent working on sponsored projects. All individuals within the University who manage sponsored projects, are involved in allocating compensation charges to sponsored projects, have committed effort (whether through salary support or cost-share) to sponsored projects, or are responsible for completing effort statements are responsible for understanding the principles of, and standards for, accurate and timely effort reporting as set forth in this operating standard.
NOTE: For direct and indirect (subawards) Federal awards issued to the University with a start date prior to December 26, 2014, Office of Management and Budget (OMB) Circular A-21 continues to govern compensation charges. For new awards and continuation awards, supplements, etc. received for existing awards with a start date on or after December 26, 2014, governance falls under Uniform Guidance.
I. Proposing Effort and Requesting Salary Support
Levels of effort proposed in any sponsored project application should be consistent with the actual effort that each individual is expected to expend on the project during the relevant project period(s). The amount of salary support requested should be determined using the individual’s Institutional Base Salary (IBS). In general, an individual’s IBS includes all amounts paid to the individual by the University as compensation for services rendered. There are certain elements of compensation, however, that are excluded from IBS. See OSP Operating Standard 500.06 - Institutional Base Salary for Sponsored Projects.
Sponsors generally consider estimates of effort (and corresponding salary requests) in project proposals to be commitments if such proposals are awarded. Individuals for whom such commitments have been made are responsible for ensuring that the commitments are met. The effort levels reported in effort statements can be a source of information on that subject, but ultimately the responsibility for meeting the commitments lies with the individual.
For Principal Investigators (PIs), the University requires a minimum of one percent (1%) effort either directly charged or provided as pre-approved cost-share on most sponsored projects. Typically, it will be more. PIs must commit and expend at least 1% effort during at least one effort reporting period of performance to accurately reflect their leadership of the project and meet this requirement. If there are multiple PIs, at least one listed PI must assume responsibility for the direction of the project and must fulfill the 1% commitment.
In addition to their work on sponsored projects, most faculty members are engaged in teaching, administrative, and other duties. Accordingly, unless the circumstances of a particular faculty member demonstrably warrant otherwise, faculty have responsibilities that would preclude them from devoting one hundred percent (100%) of their effort to sponsored activities. The Office of Sponsored Programs (OSP) will carefully scrutinize all instances where a faculty member has committed 100% effort to sponsored projects.
II. Completion and Confirmation of Effort Statements
Roles and Responsibilities
When completing an effort statement, the certifier is expected to review the payroll distribution percentages on the effort statement and determine whether those percentages reasonably correspond to the percentages of the individual’s actual effort on each project or activity. Please recognize that, within an academic setting, teaching, research, service, and administration are often inextricably intermingled. Factors such as the availability of funds should not influence the confirmation of an effort statement.
The completed effort statement must reflect all activities for which compensation is paid by the University. The total work effort expended cannot be more or less than 100% and in no case can the percentage of an individual’s salary charged to a sponsored project exceed the percentage of the individual’s total effort expended on the project during an effort reporting period of performance.
If the percentage of total effort expended in a given effort reporting period of performance is less than the percentage of salary charged to the sponsored project as reflected on the effort statement, the certifier shall indicate on the effort statement the appropriate level of effort and communicate this change to their Departmental Effort Coordinator.
At the conclusion of the effort reporting period of performance, the Department Effort Coordinator will receive a notification to access the effort system and pre-review the effort statements of all certifiers associated with their department to ensure that the committed salary charges and cost-share are consistent with the discussions that took place with the certifier during the effort reporting period of performance. If adjustments are identified, the Department Effort Coordinator should make the necessary changes to the certified effort percentages on the effort statement and follow up with corresponding adjustments in ConnectCarolina.
During the certification period discussed below, if changes are made to the effort statement by the certifier, the Department Effort Coordinator is responsible for ensuring the timely effort confirmations by certifiers assigned to their Department/Center/Institute and for effecting appropriate adjustments in ConnectCarolina. All adjustments to ConnectCarolina must be completed within 30 days after the end of the effort certification period to "true up" variances between the certified and calculated effort percentages that are beyond University tolerances.
The Department Effort Coordinator is also responsible for informing the Effort Reporting System Central Effort Manager in the event they leave the University or move to another position within the University and will no longer be serving as the Department Effort Coordinator.
- Certifier:
The certifier is the individual charged, cost-shared, or committed to a sponsored project, named on the effort statement, and responsible for confirming their effort statement.
- Department Effort Coordinator:
The Department Effort Coordinator is the individual(s) within a Department/Center/Institute who is responsible for facilitating the effort reporting process.
- Effort Reporting System Central Effort Manager:
The Effort Reporting System Central Effort Manager is located in OSP and is responsible for:
- Ensuring the effort reporting system is operating properly and effort statements are issued in a timely manner.
- Training certifiers, Departmental Effort Coordinators, and OSP staff (as needed), on this operating standard and any associated procedures.
- Serving as effort reporting system help desk, assisting certifiers and departments with troubleshooting, and granting effort reporting system access.
- Enforcing this operating standard, including but not limited to, initiating the escalation process described below.
- Department Chair/Center or Institute Director:
The Department Chair/Center or Institute Director is responsible for ensuring compliance with this operating standard by certifiers within their Department/Center or Institute.
Effort Reporting Period of Performance and University Certification Timeline
Effort statements are generated and confirmed twice a year, in six (6) month cycles, e.g. January-June and July-December. Each six-month period is referred to as the effort reporting period of performance.
The effort statement pre-review period will begin approximately 45 calendar days from the end of the effort reporting period of performance (e.g., December 31st and June 30th) and will last for approximately two (2) weeks.
The University certification period will last 60 calendar days and commences immediately after the pre-review period ends.
Certifiers have 30 calendar days to confirm their effort after the pre-review period ends and before the escalation process commences.
III. Salary Reallocation and Reconfirmation
Salary reallocations made as a result of the effort certification process must be made in accordance with University policies and procedures on salary reallocation and cost transfers.
The salary charges and cost-share of a certifier on associated sponsored projects must be accurate and in accordance with expended effort. If a discrepancy is identified between salary charges/cost-share and expended effort, the certifier is responsible for indicating the appropriate adjustment on the effort statement and the Department Effort Coordinator is responsible for making the appropriate adjustment in ConnectCarolina.
Once effort has been confirmed, only in certain, limited circumstances will subsequent salary adjustments be permitted. In these instances, the effort statement may be required to be reopened and reconfirmed. If the effort statement is reopened, the certifier will have 21 days to complete the reconfirmation, or the related sponsored project salary and fringe benefit charges will be moved to departmental non-sponsored funds.
Once the effort certification period is closed, except in certain, limited circumstances, we cannot allow an effort statement to be created where one did not previously exist.
IV. Compliance
Financial penalties, expenditure disallowances, and harm to the University’s reputation could result from failure to provide accurate effort confirmations or failure to comply with the University’s effort reporting requirements. All individuals involved in the effort reporting process are expected to abide strictly by the provisions of this operating standard.
Failure to follow the provisions of this operating standard may subject the individuals to administrative and/or disciplinary actions in accordance with University disciplinary procedures and the judgment of University leadership.
Additionally, if an effort statement is not confirmed within the timeline prescribed in this operating standard (i.e., within 30 days after the pre-review period ends) an escalation process will commence as follows: Immediately following the expiration of the 30 day certification period, the Effort Reporting System Central Effort Manager will send a memorandum to the applicable Department Effort Coordinator that includes a list of incomplete effort statements for certifiers assigned to the Department/Center/Institute with a statement for the Department Effort Coordinator to work with the certifiers to complete their effort statements in accordance with this operating standard.
If the effort statements are not confirmed within 14 days of the memorandum to the Department Effort Coordinator, the Assistant Vice Chancellor of OSP will send a memorandum to the applicable Department Chair/Center or Institute Director that includes a list of incomplete effort statements so that the Department Chair/Center or Institute Director may inform the Department Effort Coordinator to work with certifiers to complete their effort statements in accordance with this Operating Standard.
If the effort statements are not confirmed within seven (7) calendar days of the memorandum to the Department Chair/Center or Institute Director, the Vice Chancellor for Research (or designee) will send a final notice to the respective Research Dean or Center and Institute Directors that includes a list of incomplete effort statements and notify them that, if the effort statements are not certified within seven (7) days of the date of the memorandum, OSP will place the respective sponsored projects on hold and transfer all salary and associated fringe benefit charges included on the unprocessed effort statements to a non-sponsored account of the Department/Center/Institute that is responsible for the certifier’s HR assignment. Costs moved may not be transferred back to the sponsored projects at a later date without the approval of the Assistant Vice Chancellor of OSP.
Definitions
Effort Reporting: Effort reporting is the process by which the University determines and documents the expended effort on sponsored projects during each effort reporting period of performance. The effort statement documents the proportion of time devoted to sponsored projects, teaching, clinical practice, and other University activities, expressed as a percentage of total University effort. The denominator of the effort percentage must always be total University effort, irrespective of the total number of hours worked during the effort reporting period of performance.
Effort: Effort is the time spent on any University activity by an individual, expressed as a percentage of the individual’s total University effort.
Total University Effort: Total University Effort is the total of activities for which an individual is compensated by the University under their University appointment.
Although the scope of total University effort may differ among categories of individuals, the following table illustrates the kinds of activities that would typically be considered to be part of and those outside of total University effort.
Activities included in total University effort
- Externally sponsored research, which includes:
- delivering special lectures or presentations regarding specific aspects of an ongoing sponsored project;
- writing reports, articles, and manuscripts;
- participating in appropriate seminars;
- consultation with colleagues and graduate students; and
- attending meetings, conferences, and symposiums.
- Effort expended on preparing proposals for new and/or competitive renewals of existing sponsored projects.
- Departmental/University research (includes uncompensated participation in study sections, peer review of manuscripts, or unfunded effort on externally sponsored research).
- Instruction/University Supported Academic Effort, including presentations to students/trainee groups, mentoring trainees (unless specifically part of a sponsored project such as a Career Development Award), and participation in resident training.
- Clinical service effort.
- Administrative effort includes administrative activities (e.g., Department Chair, Program Director, service on institutional committees, department activities, faculty advisory boards, etc.).
Activities outside of total University effort
- Consulting and other external compensated professional work including service on Scientific Advisory boards or similar boards.
- Special activities resulting in payment or a bonus of one-time extra compensation.
- Volunteer community or public service.
- Other activities over and above, or separate from, assigned responsibilities in the primary position.
Effort Statement: The effort statement contains data indicating the percentage of the individual’s University salary that was allocated to sponsored project accounts and other University activities during the effort reporting period of performance as represented by the total University effort. The salary allocation percentages on the effort statement are not effort percentages; but rather are provided solely for informational purposes.
The confirmed effort statement serves as an affirmation by the individual completing the effort statement ("certifier") that the percentages of effort reported on the form are accurate. Knowingly signing an inaccurate effort statement is a serious violation of University policy, as well as potentially violating civil and criminal fraud statutes.
Effort reporting period of performance: The effort reporting period of performance is the six (6) month period represented by an effort statement. The University issues effort statements twice a year, in six (6) month cycles, i.e. January-June and July-December. Each six-month period is referred to as an "effort reporting period of performance".
Cost Sharing: Cost sharing is a portion of total sponsored project costs not funded by the sponsor. The type of cost sharing applicable to this operating standard is the cost share of salary charges. Effort statements must document salary cost-sharing commitments made by the University to the sponsor. Only effort shown through the effort statement may be used for meeting sponsor cost-share requirements.
Related Requirements
Unit Policies, Standards, & Procedures
Contact Information
For questions regarding this operating standard and its related procedure, please contact SponsoredPrograms@unc.edu.
For questions regarding Pre-Award management or Post-Award administration, please contact the assigned Sponsored Projects Specialist (SPS).
For invoicing, reporting and other financial matters, please contact the assigned Sponsored Projects Accountant. OSP Staff assignments are found in RAMSeS or on the OSP website.
History
History Table
| Date |
Revision |
| 07/01/2022 |
Revised to reflect the new office name. |
| 05/15/2018 |
Revised to coincide with the release of the new OSP Website. |
| 08/18/2016 |
Policy and Procedure revised to reflect the removal of the escalation period related to the reconfirmation of effort statement, adjustments to ConnectCarolina must be completed within 30 days after end of effort certification period and other administrative changes. |
| 02/13/2016 |
Policy and Procedure revised to reflect the University’s upgraded electronic effort system. |
| 09/15/2015 |
Policy and Procedure revised to reflect the revisions included in the August 2015 University of North Carolina Contracts & Grants Business Process Standards. |
| 05/28/2015 |
Policy and Procedure revised to reflect the provisions of the Uniform Guidance and corrective action plan issued in response to an audit finding pertaining to timeliness. |
| 05/18/2015 |
FAQs about Summer Effort. |
| 03/14/2011 |
Policy and Procedure revised to correspond to on-line ecrt system. |
| 07/31/2010 |
Policy and Procedure revised to clarify the institution’s anticipated transition to a planned confirmation system. |
| 12/15/2009 |
Policy and Procedure revised to reflect development of new effort reporting system standards. |
The operating standards in the Office of Sponsored Programs Operating Standards & Procedures Manual supersede any OSP operating standards, procedures and appendices previously included in the University Business Manual, a publication of UNC-Chapel Hill’s Division of Finance.