Effort Reporting (Policy No. 200.0)

Effective Date:

October 6, 2014

Version # / Revision Date:

#2 / March, 2018

Responsible Office(s):

Office of the Vice President for Research and Office of Sponsored Projects

Approval:

Office of the Vice President for Research

Policy Statement

The Office of Management and Budgets’ (OMB) Uniform Guidance: Cost Principles, Audit, and Administrative

Requirements for Federal Awards includes regulatory requirements for certifying effort expended on sponsored awards with which the University must comply.   Effort directly charged to sponsored projects and any committed cost shared effort (i.e., committed effort that is not directly charged to the award) must be identified in the University’s effort distribution/reporting system.

The principles that govern how the University must document time and effort on federal awards are in OMB Uniform Guidance which requires each grantee to maintain a system of distributing salary charges to federal awards that results in a reasonable allocation of salary charges to each award.   The salary distribution system also must include a periodic review to confirm the reasonableness of salary charges to the federal projects.

The University employs an After-the-Fact effort reporting system that provides the principal means for certifying that the salaries charged to sponsored projects are reasonable and consistent with the portion of total professional activity committed to the projects.

The following categories of University employees are certified on University generated effort reports:

  1. All faculty, graduate students, and administrative and professional employees with salary charged to sponsored projects;
  2. All non-exempt support staff, undergraduate students, and limited duration employees paid on sponsored projects.

Brown University’s Position on Implementing – Effort Reporting Policy

The University receives significant funding for sponsored projects from federal and state governments, private foundations, organizations, and industry.  There must be accurate effort planning and confirmation when these funds are expended for salaries and wages.

Effort certification is required by Federal regulations (Office of Management and Budget’s Uniform Guidance) for all compensation costs charged to federal sponsored awards.   In order to be compliant with these regulations, the University is required to have a system in place for certifying the allocation of salaries and wages associated with sponsored projects.

Purpose of Policy

The purpose of effort reporting is to provide a reasonable basis for distributing salary charges among direct activities (e.g., sponsored projects) and non-sponsored activities (such as instruction and administration).   OMB Uniform Guidance requires that the University document the distribution of activity to each individual sponsored project, including any cost shared effort (i.e., committed effort that is not directly charged to the award).

Method of Reporting

  1. At the beginning of each fiscal year and/or budget year salaries and wages are planned and distributed to various activities based on an individual’s expected effort (i.e., effort commitment proposed in sponsored project budget).   Effort distributions should be reasonable estimates of activities, recognizing that research, instruction, and clinical activity are often inextricably intertwined and estimates will be necessary in most cases.
  2. This effort distribution is normally accomplished by the department manager, in consultation with the Principal Investigator.   The effort distribution must be adjusted in a timely fashion for significant changes in effort when they become known.   If you have any questions please call the Office for Sponsored Projects (OSP)’s main line at 3-2777 for assistance.
  3. The effort planning and confirmation system must only reflect the activity (research, teaching, administration, and any other activity) for which the investigator or employee is compensated by the University.  External activities such as consulting or non-university (professional) committees are not to be included.
  4. The University is allowed to record effort as a percentage of total activities (i.e. teaching, research, administrative, including chairmanships and committee work, based on appointment or role at Brown University and compensated by Brown University, etc.) not as hours worked.   Therefore, all of an employee’s compensated activities must be reported in percentages of 100% regardless of the appointment full- time equivalent.
  5. Effort certification and labor distributions are not the same thing.
    1. Labor distribution (based on compensation) represents an initial estimate of how effort is expended and serves as a convenient document in support of activities on which the individual worked.
    2. The effort certification process is a method for confirming that charges made to sponsored awards are reasonable in relation to the work performed.   This is done by reviewing, updating and preparing salary reallocations, and, if necessary, making appropriate changes to the effort reports, and certifying effort reports.
  6. Individuals are not always paid from individual sources in direct proportion to the amount of activity provided   to support that sponsor or account.  If actual effort on a grant is greater than salary charged, and it is committed cost sharing, that cost shared effort must be captured on the Workday (WD) Effort Reporting system via the use of designated funds.

Who is Required to Complete Effort Certification Reports

Individual effort reports are required for all faculty, graduate students, administrative and professional employees, undergraduate students, non-exempt and limited duration employees with effort allocated to sponsored projects.

  1. An effort report for all faculty, graduate students, and exempt employees is required to be completed for the semi-annually (January 1 – June 30) and (July 1- December 31) in which a portion of their effort is allocated to a sponsored project.
  2. An effort report for undergraduate students and non-exempt employees, who have all or a portion of their effort allocated to a sponsored project is required to be completed on a monthly basis (by pay period)
  3. The effort report must represent, in percentages totaling 100%, a reasonable estimate of an employee’s University compensated effort for the period.

Verification & Sign-Off

All faculty certify their own effort except in limited circumstances. Exceptions to this practice require documented approval by the Director of Office of Sponsored Projects or designee.  In addition, all student effort is certified by the Principal Investigator(s) on the assigned project(s) where the student’s effort is allocated.  For all other employees, effort certification reports must be certified by the individual employee, or by a responsible supervisory official having firsthand knowledge of all the activities performed by the employee.

See the Effort Reporting Procedure and Appendix for Proxies/ Delegation forms.

NIH Salary CAP

Certain sponsors impose a limit or “cap” on the annual rate of salary reimbursement.   Nevertheless, investigators must still devote the full committed effort as proposed and awarded without regard to the salary reimbursement limitation.

NIH Salary Cap Web Site: http://grants.nih.gov/grants/policy/salcap_summary.htm​

Effort reports for individuals earning in excess of the capped amount must reflect the difference between the cap and the actual salary. For additional information see the NIH Salary Cap Policy (Policy No 400.0) for specific guidelines developed for calculating and reporting that effort.

Committed Cost Sharing (Mandatory and Voluntary)

Committed Cost Sharing must be captured and documented as outlined in Cost Sharing on Sponsored Projects (Policy No. 300.0).   Where some or all effort an individual has clearly committed to, but is not paid by, the project sponsor, that effort must be reported as unfunded activity (cost sharing).   Committed cost sharing is tracked via the WD Effort Reporting system and captured through the use of designated funds.

Department Procedures

An individual, based on worker category, will complete effort certification monthly or semi-annually during each calendar year.

The schedule for certifying effort is determined at the beginning of each calendar year based on payroll cutoff period and does not change during the year.  OSP will provide advance notice to departments prior to running semi-annual effort reports.

It is recommended that Department administrators develop an effort plan for each individual at the beginning of each fiscal year or grant budget period.  Departments are responsible for periodically reviewing effort distribution for appropriateness and accuracy of effort expended on all projects. 

All costing allocations against grants and contracts should be reviewed to ensure alignment with effort commitments made in the award agreement.  It is recommended that the review be done monthly or no less frequently than quarterly.

  • OMB Uniform Guidance requires adjustments to salary allocations (reallocations) in response to significant changes in work activity.  Reallocations are considered cost transfers and must be in compliance with the University’s Cost Transfer Policy https://www.brown.edu/research/conducting-research-brown/managing-award/award-management/cost-transfer-policy.
  • Failure to adjust salary allocations in a timely manner will result in errors to salary charges to grants, leading to over/under recovery of salaries. This is an Audit exposure which risks Brown’s ability to receive external funding.

Effort Reporting Process

Effort certification reports are generated on the schedule assigned to the worker category and will route first to department administrators- Cost Center Managers (CCMs) or Effort Certification Partners (ECPs). Automated email notifications from Workday provide an alert that effort reports have been generated for the period. CCMs and ECPs are to review the effort reports they receive for accuracy as soon as possible after the reports have been generated and have routed to their Workday inbox. Based on the worker category, effort reports, once generated, will route to department administrators as follows:

  • All effort reports for faculty, exempt and non-exempt workers and graduate students will route initially to ECP.
  • All effort reports for undergraduate students will route to CCM.

During the review process and prior to certification by the worker, costed (reallocations of pay) or non-costed (administrative) changes can be made within the effort report to reflect unpaid committed effort, cost sharing, the NIH Salary Cap, and/or to initiate a salary reallocation.  In this case, the ECP/CCM would change the effort on the report via the “Change Effort” option on the report. Changes to the report will require a reason for the change (Change Reason Code List- see Appendix B) as well as an adjustment to the percentage effort allocated to the funding source.  Regardless of the changes in distribution of effort, the total effort in an effort report must always equal 100%.

After the administrative review has been completed and any necessary changes have been made if applicable, the ECP/CCM submits the report to the appropriate worker who has been designated to certify the report.

The worker who certifies the report will review the effort report for accuracy.  If the report is true to the certifier’s knowledge, the worker will select to certify and submit the report.  If the report requires further editing because it is inconsistent with the actual effort expended, the certifier should return the report to the ECP/CCM with comments regarding the changes that are needed.  The ECP/CCM will review the comments and make any necessary adjustments and return to the certifier for review and certification to complete the process. 

If costed changes (reallocations) have been made to the effort report during the certification process, a payroll accounting adjustment (PAA) will originate from the effort report after it has been certified such that the payroll information for the worker can be corrected in Workday to accurately reflect the information contained within the effort report.

Proxies

All faculty, exempt and non-exempt workers are required to sign their own effort certifications semi-annually or monthly.  Requests for proxies for these individuals will be granted only in extenuating circumstances and in cases where the proxy indicated has first-hand knowledge of the work performed on the project by the worker.  ECPs and CCMs cannot be designated as proxies

The proxy request form can be found here.  Completed request forms should be emailed to Effort-Reporting@brown.edu.

Designees

All PIs are required to certify effort certifications for themselves and their students.  In certain circumstances, the PI may delegate this responsibility to another individual with first-hand knowledge of his or her sponsored awards.  The individual who signs the effort certifications must attest that the salaries charged and effort expended reasonably reflect work performed on the project and that the signer has sufficient technical knowledge and/or is in a position that provides for suitable means of verification that the work was performed.  ECPs and CCMs cannot be assigned as designees. 

The designee request form can be found here.  Completed request forms should be emailed to Effort-Reporting@brown.edu.

Effort Report Re-certifications

Once an Effort Report has been certified in Workday, no further adjustments to that individual’s distribution of effort are allowed unless approved by the OSP Director/designee.  Changes to previously certified effort erode the credibility of the certifier as well as the entire effort certification process.

Changes to a certified effort form (re-certifications) are not allowed except in limited circumstances.  Sufficient documentation must be provided that supports allowability and allocability and must explain why the effort was originally certified incorrectly.   An effort re-certification requires the approval of the Director of OSP or designee.

Terminating Worker Effort Reporting Process

If a grant-funded worker subject to effort reporting is scheduled to terminate from the University, the department administrator should ensure that the worker is terminated in advance in Workday as soon as possible prior to the worker’s actual departure date from the University.   Termination in advance originates business processes in Workday that will notify OSP of the grant-funded worker’s pending departure, initiates production of the effort reports that need to be certified for the worker’s effort through the termination date, and affords the opportunity for workers who certify their own effort to certify electronically or manually prior to leaving the University. 

Termination notifications received after the worker’s departure initiate a primarily manual certification process where effort certification forms must be certified by the Principal Investigator or other individual with firsthand knowledge of the work performed from a supervisory perspective because the worker is no longer available to certify.  In this case, a manual form is provided to the department administrator by OSP, which must be completed, certified by the appropriate party, and returned to OSP.  The manual certification process can be more time intensive; therefore, the recommended approach is termination in advance as previously outlined.

Report Distribution/Follow-Up/Filing & Archiving

OSP is responsible for the electronic distribution, collection and retention of all effort reports.  Individually reported data will be made available by OSP to authorized auditors.

Effort Certification Reports are to be certified by the Principal Investigator or worker within 30 days of being generated by the Office of Sponsored Projects. 

To ensure timeliness of certifications by workers in compliance with University guidelines, department administrators should utilize the Workday Effort Certification Summary Report to proactively manage the effort reporting process within their area.  This report should be reviewed on a weekly basis to determine what reports may still be outstanding in the department and in need of certification by the certifier.  Administrators should continue to follow up with certifiers who remain on the report in an “in progress” status as the respective effort reporting deadline approaches in order to facilitate resolution of such reports.

The University understands there may be exceptional circumstances that will warrant an extension.  If an extension is needed, the reason for the extension must be documented and approved by the Director of OSP or designee, in advance of the report deadline.

The extension request form can be found here.  Completed request forms should be emailed to Effort-Reporting@brown.edu.

Be advised that excessive disregard of the policy could lead to disallowed costs on sponsored projects, which could then be transferred by OSP to a departmental account.

Reminder Notices

Two (2) days prior to the Effort Certification Report (ECR) due date, a Workday generated alert will be sent to the Effort Certification Partner. This alert will not be routed to the person who is the certifier.

Delinquent Reports

First Delinquency Notification:

The first business day following the due date, the first delinquency notification process begins.

  • A delinquency memo generated by Workday will burst to the Certifiers, Effort Certification Partners (ECPs), or Cost Center Managers (CCMs) who need to take action on an effort report to remind them that the report is overdue and request completion of the assignment.  In the following fifteen days after the due date, OSP will follow up with an email reminder to the certifier/approver and copy the ECP/CCM regarding any past due effort reports.

Second Delinquency Notification:

If 30 business days have passed since the first delinquent notification was sent, and the delinquent effort certification report has not been certified, and there has been no approved extension request on file nor has a follow-up been made by the department to OSP, a second delinquency notification will be sent.

  • The second delinquency notification will be in the form of an official delinquency letter from the Director of OSP/designee and the Associate VP of Research, and is sent to the department chair/director, with a copy to the department administrator.
  • Department chairs and principal investigators and/or persons responsible for certification shall be made aware of the audit risk as a result of non-compliance with University policy.  

Record Keeping Requirement For Effort Certification Reports

All Electronic Certification Reports (ECRs) are kept online within the Workday Effort Certification System, which is the official system of record at Brown University.  Therefore all ECRs are discoverable documents by both internal and external auditors.

Definitions

Awarded/Committed Effort: The amount of effort (in percentage [%]) promised by the University in the proposal budget or the awarded effort (in percentage [%]) included in award documentation.

Cost Sharing: A portion of total sponsored project/program  costs not funded  by the sponsor. 

Committed Cost  Sharing of Effort:

  • Required by the sponsor
  • Identified or quantified in proposal
  • Condition of receiving the award
  • Represents binding commitments that must be captured and documented
  • Must be certified

Designee: Authorized delegation of certification responsibilities on a sponsored project to another individual (other than the PI) for effort certification.

Effort: The proportion of time spent on activities related to a Principal Investigator’s or employee’s duties, for which university compensation is received.  Total effort must always equal 100%.  External activities such as consulting are not included.

Effort Certification: The process by which the employee asserts in writing the correctness of employee percentage (%) of effort.

Effort Certification Partner: The administrator assigned to oversee the fulfillment of effort certification requirements for a supervisory organization within the University. 

Effort Reporting: The mechanism used to provide assurance to federal or other external sponsors that salaries charged or cost shared to sponsored awards are reasonable in relation to the work performed.  Effort reports are referred to as “certifications.”

Institutional Base Salary: Academic-year salary as well as any stipend received for performing other administrative duties, whether as a center director, department chair, or program director.

Labor Distribution: An allocation of one’s efforts to specific general ledger accounts. The general ledger documents effort in the university’s books and records. Note: Labor distribution requires a conversion of time (i.e., effort) to dollars (i.e., compensation).

Proposed Effort: The amount of effort (in percentage [%]) in any sponsored project application, regardless of whether salary support is requested.

Proxy: Authorized delegation of certification responsibilities for the PI/faculty member’s individual effort certification.

Roles and Responsibilities

The major responsibilities each party has in connection with the University’s Effort Reporting Policy are as follows:

Effort Certification Partner/Cost Center Manager

  1. Responsible for reviewing, changing (if necessary) and submitting electronic effort certification reports.
  2. Establish effective processes and controls to ensure compliance with this policy.
  3. Ensure accurate planning and confirmation of effort, including cost sharing.
  4. Oversee the effort planning and confirmation process. 
  5. Ensure payroll is in line with certified effort by completing salary reallocations; updating WD with a worker’s costing information, and documenting cost sharing.
  6. Actively track certification progress each effort reporting period and follow up directly with certifiers to ensure completion.

Principal Investigator and Workers

  1. Ensure appropriateness and accuracy of effort expended on sponsored projects.
  2. Provide updates to effort distributions, as changes become known.
  3. Review, send back (if necessary), and certify effort reports.
  4. Request sponsor approval for any effort reductions of 25% or more, paid or unpaid, on a federal grant or contract. If the PI or key personnel reduce paid effort, s/he/they may choose to document cost-sharing so that the total effort does not decrease.

Office of Sponsored Projects

  1. Develop and implement effort reporting policies, procedures, and training in accordance with the regulations set forth in OMB Uniform Guidance.
  2. Develop and deliver appropriate effort reporting training sessions.
  3. Electronically generate/distribute effort certification reports for all employees identified as expending effort on sponsored projects.
  4. Reconcile costed changes made to effort certification reports to Payroll (adjustments).
  5. Monitor the effort planning and confirmation process to ensure compliance with the University’s Effort Reporting Policy.
  6. Review effort reports to ensure reports are reviewed and accurately completed and returned to OSP on a timely basis.
  7. Report questionable practices and recurring problems to the Associate VP for Research and the Director of Internal Audit.
  8. Work with external auditors as they monitor the University’s compliance with effort  reporting regulations.

Internal Audit

  1. Independently evaluate compliance with effort reporting requirements.

FAQs

What is effort?

Effort is the portion of time spent on a given professional activity and expressed as a percentage of the total professional activity for which an individual is employed by Brown University. 

Effort considers all professional activities related to the individual’s appointment (teaching research, and administration). Total effort must always equal 100%, regardless of appointment (whether part-time or full-time equivalent) and without regard to the number of hours worked in a week.  

Why is effort reporting important?

Effort reporting is required by federal regulation as outlined in OMB Uniform Guidance, and is a process by which the salary charged to a sponsored project is reflected as commensurate to the effort contributed on that project. The federal government requires certification of effort expended by all employees whose salaries are charged to federal and federal flow- through funds, as well as for reporting committed cost sharing. Effort reporting ensures government funds are being spent responsibly and in accordance with the commitments as specified in the grant proposal.

Who should review effort reporting?

  • Effort Certification Partners (ECPs) perform the administrative review of effort certifications for faculty, staff, and graduate students.
  • Cost Center Managers (CCMs) perform the administrative review of effort certifications for undergraduate students.
  • Principal Investigators (PIs) perform a secondary review of certifications for all students.

Who should certify effort reporting?

Effort reports should be certified by responsible persons with suitable means of verification that the work was performed.

  • Faculty, or pre-approved proxy, must certify their own effort.
  • Principal investigators, or pre-approved designee, must certify student effort.
  • For all other employees, effort reports must be certified by the individual employee or pre-approved proxy. 
  • For all other employees, effort reports must be certified by the individual employee or pre-approved proxy.

Administrators should not be certifiers.  Their role is to assist with inputting percentages (%’s), dollars, etc.

When are certifications required?

Certifications are required based on frequencies noted below:

  • Monthly: Non-exempt and undergraduates
  • Semi-Annually: All other employees

At Brown, effort reports must be certified within 30* days of the report being generated by OSP. 

*Reports that will not be certified by the deadline require an extension request.  This request must be pre approved before the reporting deadline for that period by the OSP Director or designee.

What is Institutional Base Salary, and how should it be charged to grants?

Institutional Base Salary (IBS) includes academic year salary as well as any stipend received for performing administrative duties for the University, whether as a center director, department chair, or program director.  It does not include payments for bonuses, one-time payments, overtime, or incentive pay.  It also does not include income earned for work performed outside of University responsibilities.

Institutional research funds taken in lieu of compensation are not included in the calculation of IBS. 

Because administrative appointments are made on an annual basis, the stipend is considered compensation for responsibilities executed throughout the full year; by contrast, compensation for academic appointments is for work done during the 9-month, 10-month, or 12-month academic year.

When charging a portion of monthly effort to research grants, a monthly salary should be computed as one-ninth of the academic-year salary (or one-tenth, for ten-month appointments) plus one-twelfth of the administrative stipend.

What is the NIH Salary Cap? 

Every year since 1990 Congress has mandated a provision limiting the direct salary that an individual may receive funded by The National Institutes of Health (NIH). This rate is updated annually on a calendar-year basis. Further information regarding the salary cap can be found HERE. Please refer to Brown’s NIH Salary CAP Policy for further information. 

What is cost shared effort?

Cost shared effort is a commitment of Brown University’s resources/funding that supplements externally sponsored projects. This occurs when actual committed effort exceeds the salary charged to a project.  Committed cost share must be properly documented and tracked.

What is the difference between effort reporting and payroll distribution?

Payroll distributions and effort reports are not the same thing. Payroll distributions are the distribution of an individual’s salary, while effort reports describe the allocation of an individual’s actual time and effort spent on specific projects, whether or not reimbursed by the sponsor. Payroll can be expressed as an estimate of actual time worked and is the basis for generating the effort statement.

How exact should an estimation of effort be?

Sponsors recognize that the activities that constitute effort are often difficult to separate. Per OMB Uniform Guidance, effort certification can be based upon a “reasonable estimate” of effort.  The tolerance level for effort estimations is within 5%.

Do I need to notify the funding agency of a reduction in effort? 

Changes in effort should be in alignment with the grant award agreement.  Effort changes that deviate from the agreed effort as established by the proposal should be within the parameters set by the sponsor in the agreement.  For many federal awards, reductions in effort >25% require sponsor approval; therefore, sponsor terms should be reviewed before making this type of change.

As an Effort Certification Partner for my department, how do I track the status of effort certifications for which I am responsible?

In Workday, you can search for and run the WD Effort Certification Summary Report for effort report periods that have already been generated.  This report details the employee in need of certification as well as the person responsible for certification.  This report can be generated for employees that have reports that are currently in progress or who have already been certified.

As an ECP, I have to review an electronic effort report for a worker who was funded by a grant managed outside of my department.  How should I handle this report?

You should identify and contact the manager of the grant listed in the effort report, discuss the effort percentage(s) presented in the report that relate to their grant(s), and request that the grant manager verify the effort reported against their grant(s), preferably via email.  Once effort has been affirmed, you can upload the effort confirmation into the certification report or document confirmation of the effort in the comments section of the report prior to submission of the report to the certifier.

Alternatively, if you have identified the correct grant manager, you may also delegate the electronic report to that individual.  Delegation should be preceded by a conversation with the other grant manager to establish a clear understanding of what action needs to occur and the purpose of the delegation.  If there are multiple grants on the effort report, and one or more of them belongs to your department, comments should be added to the effort report to attest to the accuracy of the effort on your area’s grant(s) prior to delegation to an outside department.

If you cannot identify the correct grant manager by the grant number, contact your OSP grant accountant/effort certification administrator.

How do I obtain training for effort reporting?

Formal trainings for Effort Certification Partners (ECPs) and Cost Center Managers (CCMs) are currently offered twice yearly, typically in the summer and the fall.  You can check for training opportunities in Workday Learning. We rely on ECPs and CCMs to provide guidance to certifiers within their departments based upon their training. 

 

Do certifiers receive notifications regarding effort reporting?

Yes, when the effort report is submitted (approved) by the ECP/CCM for certification, the certifier receives an automated notification.  The certifier also receives an automated delinquency notification if the report is not certified by the due date.

Our department needs a new ECP assignment due to an administrative change.  What’s the application process?

To add a new ECP or to replace an ECP assigned to your department, first send an email to the Effort Certification Administrator (ECA) at Effort-Reporting@Brown.edu detailing the requested assignment.  If the request is approved by the OSP-Director or designee, the ECA will submit a Workday ticket on behalf of the department.  Completion of the assignment process usually takes between 2-5 business days.

How are workers assigned to an Effort Certification Partner (ECP)?  Are they assigned according to the grants on which they work?

Workers are assigned according to their position within a given supervisory organization.  A worker may not work on a grant that an ECP manages, but may hold a position within the ECPs supervisory organization and is therefore the respective ECP’s responsibility in the effort certification process.

Who do I contact for help with specific problems with the effort reporting process?

The main point of contact for effort reporting questions is the Effort Certification Administrator who can be reached by email at Effort-Reporting@Brown.edu.  Generally, you can expect a response within 24 hours.

What is the process for a manual effort certification? Where can I obtain the forms?

In some cases, it isn’t possible to complete certification electronically.  In these instances, the Effort Certification Administrator (ECA) will send a manual certification template to the Effort Certification Partner (ECP)/Cost Center Manager (CCM) upon request or as a result of receipt of a terminating worker notification.  These forms must be completed and certified by the appropriate party as outlined in the effort certification policy.  Once the ECP returns the certified form to OSP, the ECA can upload the forms into the electronic report so that the effort is still recorded electronically in Workday. 

Email Effort-Reporting@Brown.edu for the forms for the relevant periods that require manual certification.

    Contacts

     

    Subject

     

    Contact

     

    Phone

    Proposal Stage- Policy and Procedure

    Questions

    Contract Administrator

    401-863-2777

    Award Stage – Policy and Procedure

    Questions

    Grants/Contracts Accountant

    401-863-2777

    Effort Certification Reports & Cost Share

    Certifications

    Effort Certification Administrator

    401-863-2777

    Revision History

    Version 1 - New procedure – 9/30/14

    The official version of this information will only be maintained in an on -line web format. Any and all printed copies of this material are dated as of the print date.  Please make certain to review the material on-line prior to placing reliance on a dated printed version.

     

    Appendix A – Salary CAP

    Salary Cap:

    NIH and certain other sponsors limit the salary that can be charged on awards.   In cases where salary exceeds the cap, the salary charged to the sponsored project must be prorated with respect to the cap.  The effort report must be modified to reflect actual effort.  If you have  any questions please contact OSP or BMRA.

    Examples

    a. If the cap were $175,700  annually and the individual  spends 50% effort on the project during the Spring, the maximum salary that can be charged to the project during the semester is $43,925 (50%x175,7 00/2).

    b. Cap cost sharing must be reflected on the effort report. When the salary is greater than the cap, effort will be greater than the pay distribution on the effort report for that award.

    i. Assume cap is $175,700,  salary is $195,000,  committed effort  is 47%, and actual effort is 50%.

    ii. Salary to be paid from award = 42%; the effort report will only show the 42% effort charged to the award.

    iii. Cost shared salary = 5%; this effort needs to be documented  and certified.


    For additional  information please visit the NIH salary cap website

    To determine the maximum amount of salary that can be charged under the NIH cap see the Salary Cap Worksheet