EFFORT REPORTING POLICY

Purpose: To set forth in writing the University’s practice and policy for effort reporting activities necessary to comply with federal government mandates to ensure the proper charging of labor costs to federally and non-federally sponsored activities at the University of Alabama at Birmingham (UAB).

Definitions:

Departmental Research Administrator – A generic term that refers to a position (e.g., departmental administrator, division administrator, award manager, Departmental Effort Officer (DEO), etc.) with responsibility for award management as designated by the Department.

UAB Project Employee – All UAB faculty-investigators and other salaried employees including salaried student employees who have any portion of their salary paid from a sponsored project whether federally, state, or privately funded.

1. Introduction

The Office of Management and Budget Circular A-21 entitled “Cost Principles for Educational Institutions” requires that salary and wage amounts charged to federally supported projects be based on an adequate payroll distribution system that documents such distribution in accordance with generally accepted practices of the organization. This policy is intended to outline this effort reporting system for UAB and identify the effort reporting responsibility of UAB employees.

2. Personnel to Whom This Policy Applies

This Policy applies to all UAB Project Employees. This Policy does not apply to hourly-paid employees because their effort is accounted for and certified by means of biweekly timesheets. It also does not apply to some irregular employees whose effort is certified by a UAB Project Employee.

3. Policy

   A. Effort Report System.Compensation for salary, wages, and benefits may be charged to sponsored project accounts provided that they are reasonable, conform to the established policy of the organization, are consistently applied regardless of the source of funds, and reflect no more than the percentage of time actually devoted to the project (Circular A-21, Section J.10.). At UAB, the effort of UAB Project Employees is accounted for under an after-the-fact activity records system that uses a combination of personnel documents and quarterly effort reports. This system must represent a reasonable estimate of the actual work performed.

1. Personnel Documents. Distribution of salary dollars for UAB Project Employees working on grants/contracts must be specified in personnel documents based on the proportion of their assigned UAB work activities.
   
   
2. Effort Reports. UAB Project Employees must certify quarterly effort reports specifying the percent of total UAB effort on the employee’s various UAB activities. UAB activities include sponsored research, sponsored instruction, other sponsored activities and all other UAB activities (i.e. instruction, training, and administration). Certification or approval of the effort report is to be made by the UAB Project Employee, or, in some circumstances, the certification may be made on behalf of the employee by another person who has direct knowledge or suitable means of verification of that employee’s activities. Principal investigators and departmental management are responsible for ensuring that UAB Project Employees responsible for certifying their activities understand clearly which accounts represent those activities and how their effort actually relates to those accounts.
   
   
3. Timing of Effort Reports. Effort reports will be generated approximately 15 days after the end of the quarter and distributed for review and certification. Certification of effort reports is required no later than sixty (60) days after the end of a quarter. Reports not certified in this period are considered past due. Effort reports remaining uncertified after the subsequent quarter’s effort reports are generated are delinquent.

B. Calculation of Effort. The effort of UAB Project Employees on a particular project must be reported as a percentage of the employee’s Total UAB Effort.

1. Total UAB Effort consists of all activities performed on behalf of UAB. Teaching, research, and administrative activities are all services performed for UAB. Some UAB Project Employees are also employed by the Health Services Foundation (HSF) in the case of physicians, other professional practice plans in the case of dentistry, optometry, and ophthalmology, and/or the Veterans Administration for clinical activities. The time/effort and activities spent in support of HSF, other practice plans, and VA clinical activities is not performed for UAB and should not be included in Total UAB Effort. Nor are external consulting activities or activities compensated by an entity, other than UAB, included in Total UAB Effort.
   
2. There is no set number of hours that constitute Total UAB Effort. Since UAB Project Employees receive a monthly salary, regardless of the specific number of hours worked for UAB, all hours spent on work-related UAB activities (even those over 40 hours per week) must be included in the effort allocation. Total UAB Effort is all time spent in support of UAB activities, regardless of the number of hours that may constitute.

C. Changes in Status and/or Effort.

1. Sponsoring agencies have prior notification requirements for changes in personnel status and/or effort that vary by agency. Federal agencies define Changes in Status as withdrawal from a project, absence from the project for any continuous period of three (3) months or more, or twenty-five (25%) percent or greater reduction in the time devoted to the project (over the budget year) from the level approved at the time of award. UAB Project Employees are responsible for verifying and following the sponsoring agencies’ prior notification requirements related to Changes in Status and/or effort.

2. In addition to meeting the prior notification and approval requirements of the sponsoring agencies for Changes in Status and/or effort, each department is expected to have in place appropriate policies and procedures that, at a minimum, delineate approvals for changes in effort and/or salary allocation for Key Personnel, regardless of whether prior notification is required by the agency. These procedures must include approval at a level above the Principal Investigator (PI). For this purpose, “key personnel” are the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered key personnel if their involvement meets this definition. Consultants also may be considered key personnel if they meet this definition. 

3. Temporary changes of less than five percent of assigned effort per pay period are generally considered immaterial, and because of the insignificance of such shifts in effort they need not be reported on personnel documents. However, changes that are expected to be continuing should be reported on personnel documents. Changes made to quarterly effort reports will apply to that period only and will not apply to future funding periods unless personnel documents requesting the change are submitted.

D. Training Requirement. Employees covered under this policy may not have effort allocated to extramurally sponsored projects without completion of training in effort reporting on a timely basis, as required by UAB. Because of their responsibility to review effort reports and to verify that the effort listed is consistent with information provided in the sponsored project application and the salary paid during the reporting period, DEOs must also complete effort reporting training.

IV. Noncompliance

Allocation of future salary to extramurally sponsored projects is prohibited for individuals with delinquent effort reports.

1. Delinquent effort reports i.e.,  those that remain uncertified after the issuance of effort reports for the subsequent quarter, will be referred to the Office of Research Compliance for evaluation and recommendations for appropriate action relating to final resolution of the salary allocation.
   
   
2. Other instances of non-compliance with this policy (for example lack of effort reporting training) will be referred to the Associate Vice President for Research Operations and Compliance who will be responsible for appropriate follow-up.

Attachments:

Attachments to the policy may be revised from time to time without affecting the policy itself.

Implementation:

The Vice President for Financial Affairs & Administration through the Financial Affairs division and the Vice President for Research through the Associate Vice President for Research Operations and Compliance are responsible for developing, implementing, and maintaining the procedures associated with this policy. The policy, which embodies the general principles already in effect at UAB, is effective April 1, 2006, with the provisions relating to timely submission of effort reports applying to the effort reports for the first quarter of 2006.

Attachment A

Procedures

1. At both the time a grant application is submitted and the Notice of Grant Award (NGA) is received, the departmental research administrator and the Principal Investigator (PI) will review the effort declared on the grant application and approved in the award, as appropriate, for all personnel sourced to the project to verify that there are no conflicts of time committed. Any conflicts must be resolved before that person’s salary and fringe benefits can be charged to the sponsored project account.
   
   
2. At the time of NGA the UAB Office of Grants and Contracts Administration (OGCA) will review materials associated with this sponsored activity and if there are no omissions will forward the NGA to Grants and Contracts Accounting and to the appropriate departmental research administrator. Grants and Contracts Accounting will enter the new project information into the Oracle system. Once an account number has been generated the appropriate departmental research administrator will be notified. The Departmental Effort Officer (DEO) or other departmental personnel with delegated authority will determine whether or not all faculty and monthly salaried staff personnel to be assigned to the project award have completed effort reporting training. After verifying that training has been completed, the salary allocation may be entered into the Oracle System. The DEO or other departmental personnel with delegated authority will notify personnel who have not satisfactorily completed effort reporting education that this requirement must be fulfilled prior to allocating salary to a sponsored project account.
   
   
3. Effort reports will be sent to DEOs 15 days after the end of the quarter. The DEOs (or other designated departmental personnel) will review the Effort Reports and verify that the effort listed for each individual on each sponsored activity is consistent with information provided in the sponsored project application as well as with the salary paid to those individuals during the reporting period. DEOs (or other designated departmental personnel) will make necessary adjustments for the NIH salary cap, cost sharing, or other corrective measures, and notify appropriate faculty-investigators and salaried employees that the quarterly reports are available for certification.
   
   
4. UAB faculty-investigators and salaried personnel will access the Effort Reports and certify that the reported effort accurately represents the actual effort expended on the projects listed. If the information contained in the report is inaccurate, PI’s and faculty-investigators will notify the DEO of needed corrections and certify a corrected effort report when accurate; other UAB Project Employees will work with the PI and the departmental research administrators to make any changes necessary and then certify the final corrected report. Effort reports must be reviewed and certified within sixty (60) days of the end of the quarter to which they apply, otherwise effort reports will be considered past due. Notice of past due effort reports will be sent at this time and again ninety (90) days after the end of the quarter. If they remain uncertified after effort reports are generated for the subsequent quarter, they are delinquent.
   
   
5. Financial Affairs (FA) will promptly notify the Office of Research Compliance (ORC) of all effort reports that remain uncertified at the time Effort Reports for the next quarter are generated. FA will move the sponsored project salary for the current period (and subsequent periods) to the designated departmental account. ORC will initiate its review. The compliance review process will continue even if the employee certifies before the conclusion of the review. When ORC has completed its review and the employee has certified the Effort Report, ORC will notify FA and the Office of the Vice-President for Research of the findings and recommendations for corrective action based on its review including allocation of sponsored project salary consistent with expended effort for the periods reviewed. Following review and acceptance of ORC recommendations, FA will take corrective action, as necessary, and re-establish salary allocations back to the sponsored project accounts in accordance with the effort listed on personnel documents. No action is required by the department or employee. If changes are indicated in Effort Reports for other quarters, it is the responsibility of the employee and department to request the salary reclassification and/or take other appropriate action to ensure the accuracy of these reports.

QUESTIONS and ANSWERS

1. Does the policy apply to employees whose salary exceeds the federal cap (“over-the-cap”) and who currently certify their effort using paper forms?

Yes. Timely, accurate reporting of effort as required by this policy applies to all employees, including those who certify effort on paper forms rather than on-line through Oracle.

2. Why can’t I access Oracle to certify my effort when I am off campus?

Contact AskIT.

3. What happens if I don’t submit my effort report by the 90th day after the end of the quarter?

Effort can be certified at any time. If the report is submitted before the next effort report is generated through Oracle, no action will be taken; however, reports submitted after that time will be forwarded to the Office of Research Compliance. The staff of that Office will work with the employee and the Department to identify the problem and will recommend how to allocate the effort.

The following is an example of the process for handling a delinquent effort report.

The Effort Report for the 3rd quarter 2006 remains uncertified as of January 10, 2007. It is delinquent because it was due by December 31, 2006 (90 days after the end of the 3rd quarter). Financial Affairs (FA) notifies the Office of Research Compliance (ORC) that the 3rd quarter 2006 Effort Report remains uncertified at the time the 4th quarter Effort Report is available to the employee. FA moves the sponsored project salary for January 2007 and subsequent periods to the designated departmental account.

ORC initiates its review. The compliance review process will continue even if the employee certifies before the conclusion of the review. ORC works with the employee and department to get the Effort Report certified. The compliance review is completed on February 15, 2007.

If ORC determines that the allocation and percent effort are correct:

ORC notifies FA that the sponsored project salary can be transferred back to the original account(s). FA transfers sponsored project salary for January 2007 and any affected February 2007 salary; no action is required by the department or employee.

If ORC identifies errors in the allocation and/or percent effort:

ORC notifies FA of corrective actions required for the 3rd quarter 2006. FA makes corrections in allocation and/or percent effort for 3rd quarter 2006 to the appropriate accounts. If the corrective actions result in the generation of a revised Effort Report, the employee is expected to certify the new Effort Report. FA transfers sponsored project salary for January 2007 and any affected February 2007 salary back to the original account(s) at the original percent effort. No action is required by the department or employee.

However, if the 4th quarter 2006 Effort Report is not yet delinquent and changes in allocation or percent effort are needed, the employee and department are expected to make the salary reclassification and/or take other appropriate action to ensure the accuracy of reports for this quarter and any subsequent quarters. ORC may review any Effort Reports certified for quarters prior to the 3rd quarter and will work with the employee and department to make any necessary corrections.

4. What should I do if I have effort related to a sponsored activity for which the legal agreement is still being negotiated?

The department should request a “Pending” or “At Risk” account, as described below, using the form provided by Grants and Contracts Accounting. This account would be like other sponsored activity accounts, except that it will need to be reviewed periodically until the legal agreement is finalized.

At-Risk Awards
These are non-competing segments or non federal awards we get yearly.

For these we will use the current At-Risk form and no additional information is needed.

Pending Awards
These will be awards that are competing segments, transfers in awards (from other institutions) or for new awards.

The following is required at the time of the request:

1. A document from the sponsor indicating the beginning and the end dates of the award.
2. A copy of the Extramural Checklist that was submitted with the proposal and correspondence from OGCA indicating that the award is actively being worked.

5. I don’t remember whether or not I completed Effort Reporting education. How can I check?

1. Go to https://blazernet.uab.edu.
2. Log in with your BlazerID and password.
3. Go to the Courses & Training tab located at the top of the page.
4. Your last five courses will be displayed on the Training and Requirements Dashboard. If you have more than five courses, click on the Bedroc Status Page link to display your regulatory training history.

If you think you completed the course but do not see it listed, contact Fredia Fuller Dillard at eteacher@uab.edu.

6. As a DEO, what training am I required to take?

You are expected to successfully complete the Effort Reporting Training (available at www.uab.edu/trainingcourses) required of all UAB Project Employees. If you wish additional training, specifically in the use of Oracle for effort reporting, contact Cost Analysis personnel in Financial Affairs

7. The Policy says that if there is a temporary change of less than 5% in assigned effort per pay period, reporting in personnel documents is not required. Who should I ask if I have a question about the definition of “temporary” or how to determine whether or not the change is really less than 5%?

Contact Cost Analysis personnel in Financial Affairs for assistance.

Last Updated: July 2008