Retroactive Changes to Effort
I. SCOPEThis policy applies to all faculty and staff who are required to annually certify their effort (as identified in GAP 200.170) to be in compliance with University and external regulations.
II. POLICYRetroactive adjustments to effort allocations should be made on a timely basis and provide sufficient information to identify why the adjustment is occurring. The approval hierarchy is based on the timeframe of the submission of the adjusting entry.
In accordance with OMB Circular A-110, Duke University’s practices and systems are designed to ensure expenditures are charged in a timely manner to the correct General Ledger account and sponsored program. OMB A-21, Section J10.c requires that our effort reporting and payroll system “will provide for modification of an individual's salary or salary distribution commensurate with a significant change in the employee's work activity.”
Faculty members and department research administration staff are responsible for ensuring that the effort allocated to a sponsored project reasonably and accurately reflects the individual’s time. Retroactive adjustments should be made on a timely basis and provide sufficient information to identify why the adjustment is occurring. Specific guidance and documentation requirements are included in GAP 200.170, Effort Reporting.
Deadlines associated with the submission of retroactive cost adjustments are as follows:
- < 90 Days: As defined by the department
- 90 – 180 Days: Department Business Manager approval required (may require cost-sharing)
- 180 Days or Across Certified Period: Unallowable cost to federal sponsor - must be charged to institutional funds (Exceptions require Management Center / Vice Dean/Provost approval)
In all cases, an unallowable expenditure must be removed from a federally sponsored project regardless of timeframe.
Corrections made outside of this policy will be considered cost sharing and charged to the department. In support of federal regulations, a higher level of documentation is required; Departments should continue to justify corrections made more than 3 accounting periods from the date of occurrence via iForms. Adjustments that meet the above guidelines but cross a certified period are generally unallowable unless specifically authorized by the Vice Dean/Provost for Research.
III. GUIDELINEThe Office of Sponsored Programs provides Periodic Notice Effort Reports to departments on a quarterly basis (September, December, and March). The purpose of these reports is to provide departments a view of planned effort for each exempt employee so that effort can be prospectively managed and corrections can be made before the annual Effort Certifications are prepared. Review of these notices ensures the timely correction of errors. Departmental management is responsible for reviewing effort in a timely manner and processing changes according to the policy above. Adjustments across a previously certified period require additional documentation and justification.
The Office of Research Costing Compliance (RCC) will monitor compliance (allowability, timeliness and adequacy of documentation) of retroactive adjustments covered by this policy. Non-compliance will be addressed by RCC with the support of the Management Centers.
IV. EXCEPTIONSExceptions must be documented and requested through the applicable Management Center Finance Office and/or the office of the Vice Dean for Research of the School of Medicine or the Vice Provost for Research, as appropriate. Exceptional circumstances may exist, but a corrective action plan should be submitted with the request for an exception.
Violations of this policy related to lack of documentation or untimeliness do not necessarily mean that the related expenditure is unallowable from an external regulatory perspective but will generally be charged to departmental funds.
V. ADDITIONAL RESOURCES
Office of Sponsored Programs: (919) 684-5442
University Payroll Office: (919) 684-2642