GAP 200.170, Effort Reporting

I.    Purpose

II.   ECRT System (Effort Reporting)

III.  Roles and Responsibilities

IV.  Federal Regulations

 

 

I. Purpose

This procedure outlines Duke University’s definition of effort and reporting requirements when effort is expended on sponsored projects. The definition and expectations for reporting reflect the standards provided in 2 CFR 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, otherwise known as the Uniform Guidance (UG), Section 200.430 (Compensation-Personal Services).

The UG includes the following as allowable activities for charging to sponsored funds:

Activities contributing and directly related to work under an agreement, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, developing and maintaining protocols (human, animals, etc), managing substances/chemicals, managing and securing project-specific data, coordinating research subjects, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences.

Duke does not consider the following activities to be allowable to be charged to sponsored funds, but should be charged to institutional funds:

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).

Furthermore, the UG requires charges to a Federal award to be based on records that accurately reflect the work performed. Duke University uses the Effort Certification and Reporting Technology tool (ECRT), a system that allows for internal controls to provide reasonable assurance that the charges are accurate, allowable and properly allocated, as well as incorporated into Duke’s official payroll records. ECRT requires employees and Effort Coordinators to review and approve effort statements so that payroll distribution aligns with certified effort.

 

II. ECRT System (Effort Reporting)

A.  Exempt Employees

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

• The first is for the faculty or staff member's base salary, referred to as Institutional Base Salary. This is the rate at which a faculty member should charge their effort to a sponsored project. According to the UG, unless given prior approval given by the sponsoring agency, charges to federal awards in no event should exceed the proportionate share of the IBS for a given period.
  
  These rates are calculated according to the regular (base) salary distribution. 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.

 

• The second is an accumulation of the faculty or staff member's supplemental pay, paid via a Supplemental Payment Form. These charges are calculated according to the supplemental pay distribution. The weighted average percentage for an activity is calculated by adding all listed 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 listed supplemental payments for the period.
  
  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 and to support timely adjustments if necessary. 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. The faculty/staff member is not required to certify quarterly. 
  
  Following the close of each fiscal year, ECRT sends an email to applicable faculty and staff members requesting that they review and certify their effort. ECRT also sends a notice to Effort Coordinators with a list of names of faculty/staff members that were sent the Annual Effort Certification email. Each employee is required to certify effort expended on the report as correct or, if incorrect, indicate the correct percentage of effort expended on the various activities. If there are measurable changes of effort percentages (>0.9%), redistribution of payroll allocation is required. 
  
  Any errors must be corrected by preparing and submitting a Cost Distribution form through iForms, see GAP 200.150, Cost Transfers on Federally Sponosred Projects.

B.  Non-Exempt Employees

The University has a procedure for certifying staff effort for non-exempt employees. Certification of effort is completed when a timecard is submitted by the employee and approved by the supervisor.

 

III. Roles and Responsibilities

Exempt Employees:

• Review effort following the close of each quarter to ensure accuracy. Modify effort distribution as necessary.
• Review and certify effort following the close of the fiscal year in a timely manner.

Non-Exempt Employees:

• Accurately report all time worked on each timecard.

Primary Effort Coordinators:

• Review and monitor the effort certification status for all faculty/staff in their department for timely certification, using the ECRT Org Code Dashboard.
• Control the Secondary Effort Coordinator’s access AND assign the appropriate employee(s) to the Secondary Effort Coordinator.
• If the staff or faculty is not available, the Effort Coordinator assigns a person having first-hand knowledge of the effort expended by the individual to be an Effort Proxy.

Effort Proxy:

• Upon receiving notification from ECRT of their responsibility, the ECRT Proxy should ensure that they have received rights that allow them to review and certify the absent individual’s effort.
• Confirm first-hand knowledge, and review and certify effort for the individuals assigned.

Office of Post-Award Administration:

• Monitors the ECRT system to ensure that all required effort statements are certified and processed.

 

IV. Federal Regulations

This GAP reflects the provisions of the UG, which became effective December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which 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.

 

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.