Effort Certification Policy

As the steward of federal funds, CS&S is responsible for compliance with federal requirements to certify effort on federally funded projects. Failure to manage and certify effort could jeopardize opportunities to engage in federally funded work.

This policy applies to employees of Code for Science and Society or its Fiscally Sponsored Projects.

Policy

Employees who work on projects funded by federal agencies will comply with CS&S policies and agency regulations regarding the allocating, reporting, and certification of compensation.

CS&S is responsible for reasonably assuring that salary charges are accurate, allowable, and properly allocated. Thus, payroll must be certified for employees who receive salary support from federal funding agencies, or whose salary is provided as cost share on federally funded projects. Employees paid with federal funds must complete effort certification reporting at least every six months.

Employees cannot commit more than 100% of their effort to the combined allocation of federal awards and other sponsored work. Allocations of effort to federal awards must be reasonable given the employee’s non-sponsored work activities.

The effort devoted to a federal award should be consistent with the plan that was agreed to at the time of the award. Employees who are involved in proposing, executing, directing, or managing federally sponsored projects are responsible for:

• Understanding the fundamentals of effort management and payroll certification.
• Proposing, expending, and managing effort following all applicable sponsor policies and CS&S procedures.

What is effort certification?

Effort is the time a person spends engaged in a specific work activity, as a percentage of total time spent at work.

Work funded by an agreement with a federal funding agency requires accountability to support compliance with the funder’s terms and conditions.

People who work on federally funded projects are required to attest that 1) they devoted effort to the project at a level that is consistent with how the federal award paid them, and 2) that they’ve met commitments related to the project.

Effort certification is the process by which CS&S can assure a federal funding agency that work was performed in alignment with the award scope, budget, terms, and conditions. The Effort Certification Form will be used to certify effort.

Whose effort must be certified?

Anyone who charges all or part of their salary to a federal award, or who expend committed effort on a federal award (even though their salary is not charged to the award) must certify their effort.

Who certifies for whom?

A person with suitable means of verifying that the work was performed is responsible for certifying effort. This is a federal requirement that we cannot bypass.

Principal Investigators on a federal award certify their own effort. Each PI is responsible for certifying effort of staff who work on their federally funded projects.

When must effort be certified?

Effort is certified at least every six months, for the periods of performance related to the award terms and conditions.

How is effort certified?

The Effort Certification form is used to certify effort. Employees who are required to certify effort will receive an email request to certify effort via the form at the end of each period of performance. Employees have 30 days to complete effort certification.

Salary reallocation after effort certification

After effort has been certified, subsequent salary changes must be carefully reviewed.

Retroactive adjustments moving salary expenses onto a federally funded award require documentation that explains why the previous effort was erroneous and why the requested change is more appropriate. Such requests should be submitted via email. Effort will then need to be re-certified for the impacted period.

Retroactive adjustments moving salary off of federal awards require less scrutiny, although repeated reallocations indicate internal salary allocation processes need to be reviewed.

Procedure

CS&S operations assign salaries to appropriate grant funding

Project personnel expends effort on a project

At end of performance period, CS&S operations sends Effort Certification Form to Project personnel

Project personnel completes form within 30 days

CS&S operations verifies reported effort against payroll and grant data

Effort form becomes part of official auditable records

Roles and Responsibilities

Project PI and other effort certifiers

• Expend effort
• Ensure effort expended is appropriate
• Certify effort
• Understand effort of staff in order to certify effort for staff as needed
• Monitor effort commitment levels across federally funded awards

CS&S Operations Department

• Assign and allocate salaries to appropriate grant funding
• Process requests for reallocation as needed
• Ensure requests for salary reallocation are documented
• Review and process requests for retroactive effort certification
• Review proposals to ensure there is no excessive commitment of effort
• Verify that effort certifications are completed
• Review effort certification data to ensure distribution of salary is consistent with terms of federal awards
• Monitor recurring requests for retroactive salary changes and escalate if needed
• Provide training materials to effort certifiers