Effort Certification: Difference between revisions

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== Basis for Policy ==
== Basis for Policy ==


Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs.  Federal cost principles per the OMB circular A-21 “Cost Principles for Educational Institutions” require costs to be properly allocated to the program that received the benefits of the costs incurred.  See UNMC Policy No. 6100, Direct Cost for additional information.
Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs.  Federal cost principles per the OMB circular A-21 “Cost Principles for Educational Institutions” require costs to be properly allocated to the program that received the benefits of the costs incurred.  See [[Direct Cost|UNMC Policy No. 6100, Direct Cost]] for additional information.


The Effort Certification system is UNMC’s process for ensuring compliance with the payroll distribution requirements of the Office of Management and Budget (OMB) Circular A-21, which addresses "principles for determining costs applicable to grants, contracts, and other agreements with educational institutions." The policies, provisions, and cost accounting standards in A-21 are mandatory for institutions which directly or indirectly receive federal funds.
The Effort Certification system is UNMC’s process for ensuring compliance with the payroll distribution requirements of the [http://www.whitehouse.gov/omb/circulars_a021_2004/ Office of Management and Budget (OMB) Circular A-21], which addresses "principles for determining costs applicable to grants, contracts, and other agreements with educational institutions." The policies, provisions, and cost accounting standards in A-21 are mandatory for institutions which directly or indirectly receive federal funds.


In describing how to best track effort on federal projects, OMB Circular A-21 states the following: "In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate."  UNMC has determined 5 percentage points is a reasonable degree of tolerance for effort reporting estimates.
In describing how to best track effort on federal projects, OMB Circular A-21 states the following: "In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate."  UNMC has determined 5 percentage points is a reasonable degree of tolerance for effort reporting estimates.


OMB Circular A-110 Subpart C .25 (c)(3) states that “the absence for more than three months, or a 25 percent reduction in time devoted to the project by the approved project director or principal investigator” requires the prior approval of the federal sponsoring agency.
[http://www.whitehouse.gov/omb/circulars_a110/ OMB Circular A-110] Subpart C .25 (c)(3) states that “the absence for more than three months, or a 25 percent reduction in time devoted to the project by the approved project director or principal investigator” requires the prior approval of the federal sponsoring agency.


== Policy ==
== Policy ==


   
   
UNMC uses the Effort Certification Report as its method of documenting employee effort performed on federal projects. In regard to an Effort Certification Report, OMB Circular A-21 stipulates the following requirements:
UNMC uses the Effort Certification Report as its method of documenting employee effort performed on federal projects. In regard to an Effort Certification Report, [http://www.whitehouse.gov/omb/circulars_a021_2004/ OMB Circular A-21] stipulates the following requirements:


      
      
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Sponsored Programs Accounting is responsible for the administration of the Effort Certification Report system.  Effort Certification Reports are generated by Sponsored Programs Accounting and distributed to departments for review and certification.  Effort Certification Reports will be completed using the electronic Effort Reporting system in RSS (Research Support System) on the UNMC intranet.  Certification is due 30 days after distribution by Sponsored Programs Accounting and is considered delinquent after 30 days.  After 30 days, notice will be sent according to the scheduled process below unless extension has been granted by the Manager of Sponsored Programs Accounting.
Sponsored Programs Accounting is responsible for the administration of the Effort Certification Report system.  Effort Certification Reports are generated by Sponsored Programs Accounting and distributed to departments for review and certification.  Effort Certification Reports will be completed using the electronic Effort Reporting system in RSS (Research Support System) on the UNMC intranet.  Certification is due 30 days after distribution by Sponsored Programs Accounting and is considered delinquent after 30 days.  After 30 days, notice will be sent according to the scheduled process below unless extension has been granted by the Manager of Sponsored Programs Accounting.


Upon certification of an Effort Certification Report, the report is saved electronically and cannot be changed.  If after certification of an Effort Certification Report a retroactive payroll transfer is made (UNMC Policy No. 6106, Cost Transfer), a recertification will be required (see Effort Recertification Procedure).  A Recertification Report will be generated by Sponsored Programs Accounting and will be subject to the due dates and notice schedule in the Recertification Procedure.
Upon certification of an Effort Certification Report, the report is saved electronically and cannot be changed.  If after certification of an Effort Certification Report a retroactive payroll transfer is made ([[Cost Transfer|UNMC Policy No. 6106, Cost Transfer]]), a recertification will be required (see Effort Recertification Procedure).  A Recertification Report will be generated by Sponsored Programs Accounting and will be subject to the due dates and notice schedule in the [http://info.unmc.edu/media/spaccounting/unmc_effort_recertification_procedure.pdf Recertification Procedure].


It is the Principal Investigator’s (PI) and his/her department’s responsibility to accurately complete the Effort Certification Report.  Failure to complete the Effort Certification Report requirements will be grounds for corrective action up to and including placing a hold on research funding.  Notices will be sent according to the guidelines below:<br />
It is the Principal Investigator’s (PI) and his/her department’s responsibility to accurately complete the Effort Certification Report.  Failure to complete the Effort Certification Report requirements will be grounds for corrective action up to and including placing a hold on research funding.  Notices will be sent according to the guidelines below:<br />
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Any questions about this policy should be referred to Financial Compliance and Cost Analysis.   
Any questions about this policy should be referred to [http://info.unmc.edu/fincompliance Financial Compliance and Cost Analysis]].   


Effort Certification Procedure / Effort Certification Report (ECR) User Guide /  
[[Effort Certification|Effort Certification Procedure]] / [http://info.unmc.edu/media/spaccounting/unmc_effort_certification.doc Effort Certification Report (ECR) User Guide] /  


Recertification Procedure
[http://info.unmc.edu/media/spaccounting/recertificatione.pdf Recertification Procedure]


   
   


This policy updates UNMC Policy #6105 issued on 06/01/06.
This policy updates UNMC Policy #6105 issued on 06/01/06.
This page updated on Monday, July13, 2009, by dkp.
This page updated on Monday, July13, 2009, by [http://mailto:dpanowic@unmcnotes.unmc.edu dkp].
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