RSP 502–03: Certification of Sponsored Project Effort
United States. Office of Management and Budget. OMB circular A-21 (revised), Cost Principles for Educational Institutions
United States Office of Management and Budget OMB Circular A-110, as revised, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
United States Office of Management and Budget Memoranda 01-06, Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs (January 5, 2001)
Office for Research and Sponsored Projects Administration (ORSPA)
Effort reporting is the process of verifying that the actual effort performed on a sponsored project during an effort-reporting period meets or exceeds the combination of compensated effort and stated cost-share commitments to sponsored projects.
Employees compensated from sponsored projects or having a cost-share commitment to sponsored projects must certify 100 percent of their effort each effort-reporting period. Effort to be certified comprises an employee’s institutional base salary activities, regardless of the number of hours worked. Incidental work that is in excess of institutional base-salary activities (e.g., supplemental pay, intra-university consulting) and non-effort-related compensation (e.g., bonus pay, allowances) is not included in the effort to be certified.
Effort Commitment and Certification
Certification, per federal regulation, must be performed by an individual with suitable means of verification. Faculty, academic professionals, faculty associates, postdoctoral appointments, service professionals, and classified staff certify their own effort. Effort reports for graduate assistants/associates are certified by the PI. Occasionally, when the employee or PI is unable to certify the effort report, another individual with suitable means of verifying the employee’s effort may certify the effort report. It is the responsibility of the certifiers to adjust percentages in the effort report if they do not adequately reflect actual effort. Adjustments of 5 percent or greater must be made when certifying the effort report.
Minimum Effort Requirements
Sponsoring agencies expect some measure of PI effort on a sponsored project to demonstrate leadership of the project. ASU does not typically cost-share effort on a voluntary basis, consistent with its objectives of receiving fair compensation from sponsors for research and scholarly activity conducted at the university. Pursuant to OMB Memoranda 01-06, Principal Investigators and/or key personnel should devote at least 1 percent effort to their research projects, including mandatory and voluntary committed effort. The specific amount of effort beyond the minimum 1 percent is determined by the PI based on an estimate of the effort necessary to meet the technical objectives and outcomes of the project. Minimum effort requirements do not apply to some types of programs such as equipment and instrumentation or construction awards, dissertation or training grants, or other awards intended as “student augmentation,” or to limited purpose awards such as travel grants or conference support.
Sponsor-Imposed Salary Caps
Certain sponsors impose a limit (or cap) on the annual rate of salary reimbursement for a given amount of effort. The difference between the reimbursed salary (the capped amount) and the unreimbursed salary (the amount above the cap) must be funded by an unrestricted/local account. The PI/other key personnel must still devote the agreed upon level of effort irrespective of the salary cap.
Effort reporting periods will coincide with academic terms for all employees (fall, spring, summer).
Specific Agency Requirements
In no event may faculty charge more than a total of two months’ salary to NSF awards during the university’s fiscal year (July 1–June 30) unless prior NSF approval has been obtained. If other agencies have similar limitations, those must be adhered to as well; please refer to specific agency policies.
For further information on effort reports, see the Academic Affairs Policies and Procedures Manual—ACD 303, “Effort Reports.”
For further information, see:
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