Effort Certification Under Uniform Guidance
James P. Becker, Executive Director of Grants and Contract Services
This policy applies to Indiana University faculty, staff and students, including approved practice plan employees, paid all or in part on federally sponsored research accounts in order to confirm that the payroll distribution of their institutional base salary reasonably reflects their actual activity.
It is the policy of Indiana University that all faculty, staff and students paid from federally sponsored research accounts confirm their effort on such federally sponsored program accounts by means of effort certification. Effort certification documents shall be issued at standard intervals and must be reviewed, corrected (if applicable) and approved within 60 days after issuance. Effort certification documents include all activities for which the individual is earning their institutional base salary.
The purpose of this policy is to provide direction with respect to documentation of personnel expenses on federal and federal pass through awards at Indiana University in order to accurately reflect the work performed on those awards in accordance with the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Effort certification documents are issued at standard intervals throughout the year as detailed on the ORA website.
For each employee paid from federal or federal pass through awards, effort certification documents are routed for approval in the Indiana University financial system. The individuals in the document routing have the responsibility for verifying that the effort provided by the employee on the various projects corresponds to the pay distribution across those projects.
Effort certification documents may only be certified by persons who can personally verify the activity of the individual on the effort certification document. Individuals capable of verifying the effort would include the employee, the Principal Investigator, or a responsible official using suitable means of verification that the work was performed.
Individuals in the document routing may approve the effort certification document only if they can personally verify, (i.e. have first-hand knowledge of) the activity of the employee.
If they cannot personally verify the activity of the employee, they may do one of the following:
1. Ad-hoc route the document to another Indiana University financial system user who can verify the individual’s activity.
2. Attach an e-mail or other electronic document from an individual who can verify the individual’s activity and can confirm the effort distribution onto the Notes and Attachments panel of the effort certification document.
3. Some departments or units track employee effort through timesheets signed by the employee that record not only hours worked but also the specific projects or activities of the individual. In such cases, the timesheets may serve as sufficient documentation to approve the effort certification document.
Effort certification documents must be reviewed, corrected (if applicable) and approved within 60 days after issuance by ORA.
For Indiana University effort certification documents still unapproved at 60 days past issuance, all salaries (effort) posted to federally sponsored projects appearing in the effort certification document(s) in question will be removed to a non-sponsored account unless an exception to the certification and approval deadline has been granted by ORA.
The exception process is as follows:
1. Exceptions to the effort certification and electronic document approval deadline may be granted by ORA for certain extenuating circumstances. Examples would be an extended illness of the certifier or a change in departmental personnel that delayed certification.
2. Requests for exception must be formally communicated to ORA via e-mail at least five days before the certification deadline. E-mails may be sent to ORA_ACE@indiana.edu.
3. Upon approval of the request by ORA a defined extension period will be communicated to the requestor. A maximum of two certification extensions may be granted, each in 14-day increments.
Delinquent effort certification documents pose a significant audit risk for the university. Repeated exception requests indicate poor internal controls and will be heavily scrutinized by ORA. Ongoing problems will be elevated to departmental senior administration.
Retroactive Payroll Adjustments / Payroll Corrections
Retroactive adjustments to employee payroll that post to sponsored research accounts after effort certification documents are generated will be treated as late cost transfers and will be subject to additional scrutiny by ORA. Retroactive payroll adjustments that increase payroll charges on sponsored projects are generally not allowed.
Approved Practice Plan Effort
Those Indiana University departments authorized to recover approved practice plan employee salary costs through sponsored research accounts are responsible for approved practice plan effort certification and must follow the guidelines established in this policy.
Approved Practice Plans: Those practice plans approved by Indiana University to recover salary costs related to research conducted under the auspices of Indiana University.
Effort certification documents: Personnel activity reports that are issued periodically by ORA for each individual paid or cost-shared on a sponsored research account. Effort certification documents are based on the individual’s salary and wage distribution by account/project and are routed to the fiscal officer, account delegate, or effort certification delegate of record for each account on the document.
Suitable Means of Verification: At Indiana University “suitable means of verification” includes any documentation, including e-mail documentation, sent directly from the employee, supervisor or Principal Investigator of a specific sponsored project (account) listed on the effort certification document stating exactly the effort period, document number, account number(s), and applicable percentage effort allocation(s).
Institutional Base Salary: The annual salary received for a payroll appointment. At Indiana University this is defined as base pay applicable to an appointment. This includes, if appropriate, compensation from both Indiana University and an approved practice plan.
Failure to certify and approve effort certification documents within communicated timeframes and deadlines may result in removal of effort from any federally sponsored project included in the effort certification document to a non-sponsored account, or in the case of recovered approved practice plan compensation, the effort would be moved to a non-sponsored account.
Inaccurate or misrepresented effort certifications pose a significant audit risk to the university and will result in removal of the effort in question from the project.