GAP 200.170, Effort Reporting

  1. Applicability
  2. General
  3. ECRT System (Effort Reporting) – For Exempt Employees
  4. Non-Exempt Employees: Personnel Activity Reporting System
  5. Standards For Acceptable Methods Of Plan-Certification (From OMB Circular A-21)
  6. Independent Internal Evaluation – Annual Effort Certification Process

 


 

I. APPLICABILITY

Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133. Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance). It is important to verify the appropriate regulations applicable to your award. Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency.

These guidelines pertain to Federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-Federal sponsor’s policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc. Unless otherwise noted, this GAP applies to all sponsored projects.

 

II. GENERAL

This procedure describes how Duke defines effort and the reporting requirements of OMB Circular A-21.  We have two types of effort, University Effort (i.e., Institutional Base Salary (IBS)) – The amount of time spent ONLY on University activities, including, research, instruction, and administration and Total Professional Effort (TPE) which represents time spent on ALL Duke-related activities, including PDC and Durham VA effort.

What should be included in Sponsored Research Effort

Regardless of where effort is expended (office, home) or when (after hours, on vacation, on weekend), these items should be included in your sponsored research effort. 

Effort on current Federal Grants or contracts (e.g., NIH, NSF, or DOD), effort on current non-federal research projects (e.g., a foundation grant or industry clinical trial), writing progress reports, lab meetings, attending a scientific conference, or reading scientific journals.

What should NOT be included in Sponsored Research Effort

These activities must be funded at an appropriate level by your department or discretionary account.

Instruction and administration, which includes writing grant proposals (including competing renewals), department meetings, supervising students in non-grant related activities, interviewing students, participation on Institutional Committees such as search committees, Institutional Review Board (IRB) or Institutional Animal Care & Use (IACUC).

Effort reporting at Duke University uses two options to meet the requirements of OMB Circular A-21. The circular requires the University to document the distribution of effort and salary that its faculty and employees expend either directly or indirectly in support of federally funded projects.

The two effort reporting options are as follows:

  • Plan Confirmation - Used for all monthly paid faculty and staff members. (Effort Certification Reporting Technology [ECRT] is used to maintain quarterly notifications and annual certifications of effort).
  • Personnel Activity Reporting - used for all bi-weekly paid employees (the employee time card is the certification of effort and distribution)

The ECRT system and Personnel Activity Reports interface with the HR/payroll system to accumulate payroll data. Standards for acceptable methods of plan-confirmation are listed in Section IV of this document.

 

III. ECRT SYSTEM (EFFORT REPORTING) – FOR EXEMPT EMPLOYEES

A. Overview

There are two types of Effort Certification reports for exempt employees.

  • The first is for the faculty or staff member's base salary.
  • The second is an accumulation of the faculty or staff member's supplemental pay, paid via a Supplemental Payment Form.

At the end of each of the first three quarters of the fiscal year, ECRT sends an email to applicable faculty/staff members requesting that they review their effort to ensure accuracy. ECRT also sends an email to their Effort Coordinator with a list of names of faculty/staff members that were sent the Quarterly Effort Review email. If applicable, the individual’s Total Professional Effort (TPE) is also available for review. This quarterly notice serves as a notification of how the individual's effort is being distributed so that it can be modified if necessary.

At the end of each fiscal year, ECRT sends an email to applicable faculty and staff members requesting that they review and certify their effort. ECRT provides actual salary, supplemental pay distributions, and the percentage of annual effort for the entire fiscal year. ECRT sends an email to their Effort Coordinator with a list of names of faculty/staff members that were sent the Annual Effort Certification email. Each employee is required to certify that the actual effort expended if the report is correct or, if incorrect, indicate the correct percentage of effort expended on the various activities. If there are significant changes of effort percentages, redistribution of salary may be required. If applicable, the individual’s Total Professional Effort (TPE) is also available for confirmation.

B. Quarterly Effort Review Notice

After the September, December and March pay cycles, after ECRT has been updated with any necessary changes for those pay cycles, the Base Card and the Supplemental Pay Card (if applicable), are available for review by the employee and the Effort Coordinator.

Regular (base) salary distribution calculation: The weighted average percentage for an activity is calculated by adding all base salary payments during the period for the activity and dividing this amount by the grand total of all base salary payments for the period. Thus, the percentage for an activity is the total cost charged to an activity as it relates to the grand total of base salary  payments for the period. This methodology is appropriate for a staff or faculty member regardless of the term of appointment.

Supplemental pay distribution calculation: The weighted average percentage for an activity is calculated by adding all supplemental payments during the period for the activity and dividing this amount by the grand total of all supplemental payments for the period. Thus, the percentage for an activity is the total cost charged to an activity as it relates to the grand total of supplemental payments for the period.

Any errors must be corrected by preparing and submitting a Cost Distribution form through iForms, see GAP 200.150, Cost Transfers on Sponsored Projects. The faculty/staff member is not required to certify quarterly.

The Office of Sponsored Programs monitors the ECRT system to ensure that all applicable faculty/staff members receive the Quarterly Effort Review Notice and that appropriate Effort Coordinators are also notified.

C. Annual Certification Reports

After the June monthly pay cycle and after the ECRT system has been updated with any necessary adjustments, the Base Card and the Supplemental Pay Card (if applicable), are available for review and certification by the employee and approval by the Effort Coordinator. The distribution percentages are calculated for the Certification Reports the same way they are calculated for the Quarterly Notices.

The Office of Sponsored Programs monitors the ECRT system to ensure that all applicable faculty/staff members receive the Annual Effort Certification notice and that appropriate Effort Coordinators are also notified. 

The Effort Coordinator, via the ECRT Org Code Dashboard, reviews and monitors all faculty/staff members in their department to ensure timely review and certification of the Effort Card(s).  If the staff or faculty member is not available, the Effort Coordinator assigns a person having first hand knowledge of the effort expended by that individual – ECRT Proxy.  The ECRT Proxy is given rights that allows them to review and certify the absent individual’s Effort Card(s).  Once the Proxy is assigned, ECRT notifies the Proxy via email of their responsibility.

If the actual annual percentage of effort is different from that shown on the Effort Card, the Certifier can enter the actual percentage in the certified annual effort column of the Effort Card. The total percentages must equal 100%. A Cost Distribution form through iForms must be submitted correcting the error or errors in accordance with GAP 200.150, Cost Transfers on Sponsored Projects.

The Office of Sponsored Programs monitors the ECRT system to ensure timely certifications. 

 

IV. NON-EXEMPT EMPLOYEES: PERSONNEL ACTIVITY REPORTING SYSTEM / EFFORT CERTIFICATION REPORTING

Duke University is responsible for obtaining certifications on staff effort for salaries charged directly on sponsored projects. Please refer to GAP 101.5, Time Reports- General, Section III, Biweekly Payroll for the specific procedures.

The general procedure for certifying effort for non-exempt employees is outlined below.

The payroll labor distribution system produces a preprinted time report for each employee for each biweekly time period. The employee completes the time report by entering hours worked (including all applicable premium hours) and not worked (but for which payment is being claimed, e.g., vacation, sick leave, etc.) and certifies the accuracy of the data.

The person who has first hand knowledge of all work performed by the employee reviews the report, certifies the correctness of the hours recorded, and certifies that the distribution of wages for the period represents a reasonable estimate of the actual effort expended. When distribution corrections are necessary, submit a Biweekly Direct Code Charge Report to reflect the correct distribution, in accordance with GAP 100.523, Time Reports - Biweekly Direct Code Charge Report. Corrections made after the pay period is closed are done by completing a Cost Distribution form through iForms, in accordance with GAP 200.150, Cost Transfers on Sponsored Projects. This process reconciles the Personnel Activity Reporting System with the cumulative payroll information recorded in the general ledger.

Each department accumulates the time reports for their employees, retains the yellow copy, and sends the originals to Corporate Payroll Services for processing. The yellow copy of the timecard is retained to compare to the actual charges as reflected on the Accounting View of Payroll reports. This detects keying errors and reduces the possibility of someone falsifying the time report after it has been approved.

Note: The distribution on the time report is the latest distribution available at the time the primary and secondary time reports are prepared and sent to the departments. If a Staff Change Form has been submitted subsequent to the distribution of the time report, and prior to the close of the pay period for which the time reports represent, write "STAFF CHANGE FORM SUBMITTED" across the distribution codes to indicate knowledge of the change that has been submitted.

 

V. STANDARDS FOR ACCEPTABLE METHODS OF PLAN-CERTIFICATION (PER OMB CIRCULAR A-21)

Plan-Confirmation
Under this method, the distribution of salaries and wages of professorial and professional staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity, updated to reflect any significant changes in work distribution. A plan-confirmation system used for salaries and wages charged directly or indirectly to sponsored agreements must meet the following standards:

  1. A system of budgeted, planned, or assigned work activity will be incorporated into the official records of the institution and encompass both sponsored and all other activities on an integrated basis. The system may include the use of subsidiary records.
  2. The system will reasonably reflect only the activity for which the employee is compensated by the institution (compensation for incidental work described in subsection a need not be included). Practices vary among institutions and within institutions as to the activity constituting a full workload. Hence, the system will reflect categories of activities expressed as a percentage distribution of total activities.
  3. The system will reflect activity applicable to each sponsored agreement and to each category needed to identify F&A costs and the functions to which they are allocable. The system may treat F&A cost activities initially within a residual category and subsequently determine them by alternate methods as discussed in subsection b(2)(c).
  4. The system will provide for modification of an individual's salary or salary distribution commensurate with a significant change in the employee's work activity. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term, such as an academic period. Whenever it is apparent that a significant change in work activity which is directly or indirectly charged to sponsored agreements will occur or has occurred, the change will be documented over the signature of a responsible official and entered into the system.
  5. At least annually a statement will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed, stating that salaries and wages charged to sponsored agreements as direct charges, and to residual, F&A cost or other categories are reasonable in relation to work performed.
  6. The system will provide for independent internal evaluation to ensure the system's integrity and compliance with the above standards.
  7. In the use of this method, an institution shall not be required to provide additional support or documentation for the effort actually performed.

VI. INDEPENDENT INTERNAL EVALUATION – ANNUAL EFFORT CERTIFICATION PROCESS

In accordance with OMB A-21, j. (10), an independent internal evaluation of the effort reporting system’s integrity and compliance is conducted on a regular basis and reported to the University’s Research Costing Compliance Officer.

 

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.