Effort Certification: Difference between revisions

[[Sponsored Programs]] | [[Direct Cost]] | [[Facilities & Administrative Cost]] | [[Institutional Base Salary]] | [[Unallowable Cost Policy]] | [[Sponsored Project Cost Share]] | [[Effort Certification]] | [[Cost Transfer]] | [[Service Center]] | [[Subrecipient Policy]]

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== 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 [[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 [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.

[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 ==

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:

== Effort Certification Report Process ==

The Effort Certification Report provides the basis for certifying that salaries are charged to programs/projects in accordance with the relative activity applied to various programs and projects. The Effort Certification Report constitutes the primary basis for reimbursement to UNMC by the federal government for salaries paid from sponsored research, sponsored instruction, and other sponsored activities, as well as providing the basis for certain costs that are reimbursed as facility and administrative costs. The Effort Certification Report also provides the means of identifying cost sharing activity on sponsored programs.

The information reported by departments for the period being reported reflects the actual effort of each employee, as well as it can be estimated or measured. Reports are prepared for employees who are paid at least partially from federally sponsored projects or having cost sharing activity.

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 ([[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].

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