A.
Purpose of Certification. 1
C.
Roles and Responsibilities. 3
D.
Additional Guidance Related to Effort . 4
E.
Directions for Completing the Effort Certification Report 5
Federal
and state agencies, private foundations, organizations, and industry sponsors
provide significant funding to enable Loyola University of Chicago to conduct
research projects. Completion of
the effort certification report provides the principal means for verifying that
the salaries and wages charged to or contributed to sponsored projects are
reasonable and consistent with the portion of total professional activity
committed to the projects. Section
J.10 of OMB circular A-21 provides the framework for acceptable
methods of documenting the effort of employees on sponsored projects.
The
following sections provide more detailed explanations of effort reporting at
Loyola. For questions about this
policy, contact the Director of SPA on the Lakeside campus or the SSOM Associate
Dean of Fiscal Affairs on the Medical Center campus.
Effort
is the proportion of time spent on any activity and expressed as a percentage of
the total professional activity for which an individual is employed by
Loyola. Effort reporting is a means
of verifying that:
The
effort report documents the proportion of work time devoted to sponsored
projects, teaching, clinical practice, and other activities expressed as
percentage of total employed time (not total hours). It
is important to consider that effort is not calculated on a 40-hour
workweek. If an investigator works
80 hours in a week, 40 hours represents 50% effort. The total time employed by Loyola
constitutes 100% effort. For
example, for a graduate student who is employed for only 16 hours by Loyola, the
16 hours
represents
100% effort. The total effort expended cannot be more or less than
100%.
Why is
Effort Reporting Important?
Salaries
and wages typically comprise the majority of direct costs charged to sponsored
projects, therefore it is important to verify that salary and wage charges are
appropriate. Appropriately
certified effort reports provide auditable documentation to demonstrate
to sponsors that they received the level of effort described and expected
through the proposal process, the award process, and all post award
communications with the sponsor.
Both direct and indirect costs may be disallowed and penalties imposed
after reimbursement if auditors find such documentation to be inadequate. In addition, criminal charges may be
brought against the individual certifying falsified effort.
Who
Should Certify Effort?
Every
person who works on a sponsored project, whether paid or unpaid, is required to
certify effort. A responsible
person must review and confirm that the salary charged and effort committed on
the proposal is reasonable in relation to actual effort spent. It is critical that a person with
first-hand knowledge of all of an employee’s effort certify for the
employee. Faculty must certify
for themselves and direct supervisors can certify on behalf of others.
When
Should Effort be Certified?
Effort
Certification Reports will be issued four times per year. The timeline for distribution and
completion of the reports by the certifier is as
follows:
|
Effort
Certification Period |
Effort
Reports Issued |
Due
Date for Completed Effort Reports |
Q1 – 7/1 through 9/30 |
11/15 |
12/1 |
Q2 – 10/1 through 12/31 |
2/15 |
3/1 |
|
Q3 – 1/1 through
3/31 |
5/15 |
6/1 |
|
Q4
– 4/1 through 6/30 |
8/15 |
9/1 |
What
Should be Certified?
All of an employee’s effort for Loyola University of Chicago should be certified, whether spent on research, teaching, clinical activities, or other activities. The total effort certified on the effort certification statement must total 100%.
Principal
Investigator
The Principal
Investigator (and Co-Investigator) ensures the appropriateness and accuracy of
all effort expended on the sponsored projects and complies with the Effort
Policy. Certifies direct-charged and committed cost-shared effort up to the
effort level committed on a timely basis. On federal projects, obtains prior
approval from the Senior Associate Dean for Research if absent for more than
three consecutive months, or effort is reduced more than 25% from the budgeted
awarded plan. Communicates issues
or errors to department administrator.
Research
Employees
Research employees
certify their own effort or ensure that a faculty member certifies their effort
on a timely basis (assuming the faculty have first hand knowledge of all of the
research employees’ activities).
Communicate issues or errors to department administrator.
Sponsored
Programs Administration Office (SPA)
Sponsored
Programs Administration (SPA) develops university-wide effort reporting policy
and ensures that procedures are effectively implemented at each campus to meet
federal regulatory requirements.
For the Lakeside Campus, SPA will be responsible for ensuring that the
effort system produces accurate effort statements in a timely manner. SPA will monitor the effort process for
timely submission and will process payroll cost transfers that result from
certification. SPA will develop and
implement educational programs for all Lakeside employees involved in the effort
certification process (in coordination with the SSOM Office of Fiscal
Affairs). SPA will report their
findings to the University Controller and the Vice President of
Finance.
SSOM Office
of Fiscal Affairs (OFA)
The SSOM Office
of Fiscal Affairs (OFA) will be responsible for implementing policies,
procedures and systems to support the effort reporting process on the Medical
Center Campus campus. OFA will be
responsible for ensuring that the effort system produces accurate effort
statements in a timely manner. OFA
will monitor the effort process for timely submission and report findings to
SPA. OFA will develop and implement educational
programs for all SSOM employees involved in the effort certification process (in
coordination with SPA).
SSOM Office
of Research Services (ORS)
The SSOM Office
of Research Services (ORS) provides oversight and guidance during pre-award process
for potential issues related to effort reporting. Reviews research applications for
correct institutional base salary, resolves potential over-commitment of effort with faculty and
department.
Department
Administrator
Department
Administrators facilitate the department effort certification process.
Administer timely payroll corrections prior to issuance of effort reports. Perform pre- and post- review of effort
certification statements. Assist
faculty and staff with issues, errors, or inquiries.
Department
Head
The Department
Head establishes effective processes and controls that will ensure compliance
with the Effort Policy. Reviews
research applications for potential issues related to effort reporting
(institutional base salary, over-commitment of effort, etc.) Provides local oversight to department
during effort certification process.
Dean
The Dean provides general oversight and issue
resolution.
Vice
President for Finance
The Vice
President for Finance oversees the formulation of the University's Effort
Policy.
· Veterans Affairs (VA) Appointment (Medical School only)
· Summer Salary
The
format of the effort certification report has changed from that of prior periods
to simplify the certification process.
The new format arranges the salary paid over the quarter by project and
then by payment date, rather than by payment date and then broken down into the
individual projects. This will only
require one verification of effort per project, rather than verifying effort for
each project on each payment period.
The
payroll information on the effort certification form is now downloaded directly
from Loyola University Chicago’s payroll system; therefore, the salary payments that are shown are
correct and do not need to be verified at this time. (Please remember, the investigator
and/or departmental administrator should be reviewing the salaries that have
been or should be charged to an accounting unit on a bi-weekly or monthly
basis.)
The
investigator is responsible for confirming the percentage of overall effort
expended by the employee on the investigator’s accounting unit(s)
only. The other accounting unit(s) are shown
only in order to calculate the percentage of salary paid by the project budget
as compared to the total salary of the employee. The investigator is not responsible for the
certification of the other accounting unit(s).
Please
indicate confirmation in one of the following two
ways:
1. If the
percentage of salary equals approximately the percentage of effort placed by the
individual on the project, then indicate approval by either checking or
initialing the effort percentage box for the project that you are
certifying.
2. If the
percentage of effort is materially different than the percentage of salary paid
from an individual project, please indicate your estimate of the percentage of
effort expended by the individual on the project in the box for the effort
percentage.
If the
employee works on another project from which he/she is not paid, please indicate
the accounting unit, project title, and the percentage effort in the open boxes
at the bottom of the project listing.
After
certification, please sign and date the form(s) and return to SPA at
13th Floor, Lewis Towers, Water Tower Campus
(WTC).
The
Effort Reporting System (ERS) is a Web-based system developed by the SSOM Office
of Information Systems group. It
integrates data from the LUC Lawson General Ledger/Payroll System and the SSOM
Research Channel.
Department
administrators, division administrators in those departments with divisions or
grant managers if delegated by the department administrator are responsible for
the pre review, post review and overall management the effort certification
process in their department.
The ERS provides reviewers and certifiers a work list to manage the
process. The work list displays
each individual certification statement and allows for management of the
certification process.
The pre
review and post review functions are key to the accurate completion of effort
statements.
The
process starts with the pre reviewer reviewing the Effort Statement. Upon the pre reviewer’s release, an
email notifying the certifier that the statement(s) is available will be
generated. The certifier may either
certify the statement or notify the department administrator (pre reviewer) with
a problem or question. Once
certified, an email is generated notifying the post reviewer of the certified
statement. After review by the post
reviewer, if no changes are required, the post reviewer releases the
statement. If changes are required
the post reviewer is responsible for initiating those
changes.
The
Lawson payroll transactions are available 5 business days after the end of the
month. The pre reviewer can view
the system at any time but will only initiate action once all three months of
the quarter are complete.
The pre
reviewer is responsible for reviewing the Effort Certification Statement before
the certifier can access it. The
certification statement contains information populated from the Lawson Payroll
System (Payroll $) and the SSOM Research Channel (Committed Effort
%).
The
system automatically calculates the voluntary and mandatory cost share amounts
for each project if applicable as follows:
If
during pre review, the payroll distribution needs adjustment, the pre reviewer
will place the statement on hold and initiate the appropriate action. Once the results of the action are
reflected in the ERS, the effort statement can be released for
certification.
Reasons
to place a certification statement on hold may include:
Once the
pre reviewer completes the review of the Effort Certification Statement, the
certifier receives an auto-generated email notifying the certifier that their
statement is ready for certification.
The email will also contain the link to log into the
system.
The
certifier will enter an effort percent for each sponsored project and a total
for non-sponsored (University) accounts.
The Grand Total of Certified Effort % must equal 100%.
The
certifier has the ability to certify the statement or place the statement on
hold pending clarification of questions.
If the statement is put on hold, an email will be generated to the
department administrator for resolution.
Once the
statement is certified, an auto-generated e-mail will be sent to the post
reviewer. If any differences exist
between the certified effort % and the committed effort % the same adjustments
available in pre review are available in post review.
Link to
the Effort Reporting System
Pre
Review and Post Review Manual
Certification
Manual
At any
time, the University’s cognizant agent, the Department of Health and Human
Services, may perform an audit to determine whether the Effort Certification
Reports are accurate and complete.
Severe penalties, cost disallowance, and reduced or terminated funding
could result from inaccurate, incomplete, or untimely effort reporting. As a result, the institution has zero
tolerance for those investigators that fail to comply. The following actions will be undertaken
when a Principal Investigator does not complete his/her effort
report(s).
1. SPA or Fiscal Affairs will
expect a response within 2 weeks of issuance of the Effort Certification Reports. A follow-up email will be sent to those
Principal Investigators with outstanding reports.
2. Within
one (1) week of the e-mail, the signed Effort Certification Report(s) should be
received. Non-compliance within
this time frame will result in email notification to the departmental chair and
dean.
3. Failure
to return the signed Effort Certification Report(s) within two weeks of the
notification to the chair and the dean will result in the inactivation of the
grant accounting unit. All
transaction processing will cease until an attempt is made to comply with the
Effort Certification requirements.
Certification –
Assert in writing the correctness of something.
Cost
Sharing –
Mandatory or voluntary effort expended on one project and paid for by another
funding source. Certain sponsors
require mandatory cost sharing at the time of application and this must be
verified in the effort reporting system.
Voluntary Committed Cost Sharing represents effort that was committed to
the sponsor above the percent of payroll charged to the project. This must be verified during the effort
certification process. Voluntary
Uncommitted Cost Sharing represents effort expended above any commitments to the
sponsor and is not required to be certified in the effort reporting system.
Effort – Work
or the proportion of time spent on any activity and expressed a percentage of
total time. The effort reports are
intended to record the total effort an individual expends as an employee of
Loyola University of Chicago.
Institutional
Base Salary – The
annual compensation paid by Loyola University for an employee’s appointment,
whether that individual’s time is spent on research, teaching, patient care, or
other activities. Base salary includes Loyola’s guaranteed base and supplemental
pay, and excludes the variable incentive component. (For SSOM, the incentive component is
referenced as “bonus” for LUPF and
as “incentive” for the BSI plan).
Base salary also excludes any income that an individual is permitted to
earn outside of duties for Loyola University.
Percent
Effort – Total
number of hours worked on a sponsored project divided by the total number of
hours worked for Loyola University of Chicago. The total must equal 100 percent. For example, if an Investigator works 30
hours a week on a research project and 20 hours a week on teaching, the research
project is receiving 60% effort (30/50).
Principal
Investigator – The
individual that has been assigned the responsibility to carry out the sponsored
project. Also referred to as the
budget administrator.
-
If an
effort report is found to be inaccurate for any reason, including but not
limited to a late cost transfer, the effort report must be recertified.
-
When a
Principal Investigator is absent in excess of 90 days from his/her project,
approval must be obtained from the Senior Associate Dean for Research. The sponsoring agency must ultimately
approve the absence.
-
Changes
in effort require approval from the SSOM Dean’s Office or the Office of
University Research Services as appropriate.
-
Time
spent in the preparation of proposals (other than continuation proposals) cannot
be charged to a sponsored accounting unit.
Therefore, it is inappropriate for an employee to be paid entirely from
sponsored accounting units to prepare and submit proposals.
-
The NIH
awards currently have a salary cap of $180,100 per year effective January 1,
2005. NIH investigators earning
rates higher than the salary cap must cost share their additional salary from
University accounting units. Please
note that this means that the maximum that can be charged to the NIH accounting
unit is the percentage of effort as applied to the cap. For example, if an investigator earning
over the cap expends 25% effort on a project, the maximum that can be paid from
the account is $45,025 ($180,100 x 25%). If the investigator is earning
$200,000, then the difference of $4,975 ($200,000 x 25% - $45,025) must be
funded from a University account.