Subject: Effort Certification Policy
PURPOSE
The purpose of this policy is to describe the RF’s policy with regard to faculty
effort reporting and its relationship to cost-sharing.
BACKGROUND
Effort reporting is a process mandated by the federal government by which the
salary charged to a sponsored project is certified as being reasonable in relation
to the effort expended on that project. Effort reports constitute one of the primary
auditable documents to support salary costs on a sponsored project.
GUIDELINES
The Research Foundation of CUNY uses the “after-the-fact activity records”
method to meet the A-21 requirements of reporting faculty effort. Under this
method, personnel activity reports (PARs) reflect an after-the-fact reporting of the
distribution, by percentage, of an employee’s total salary received as reportable
compensation. The report must be signed by the Principal Investigator or
Responsible Official at the College as confirmation that it represents a
reasonable estimate of the percentage of effort performed by the employee
during the period.
Accounting for Faculty Effort
Effort on any particular project is measured as the percentage of the total
obligation to the College. This obligation includes teaching, organized research,
departmental administration, committee activities, etc. While the total number of
hours worked may vary from month to month, total effort for each period must
be expressed as 100% on the faculty member’s PAR.
Minimum Effort on Sponsored Awards
With certain exceptions (including, for example, equipment & instrumentation
grants, doctoral dissertation grants, faculty mentors on institutional training
grants), faculty are expected to apply some level of effort to projects on which
they are listed as the PI or as key personnel (1% or more or the minimum
required by the program).
Maximum Effort on Sponsored Awards
For faculty participating in activities not directly related to work on active
sponsored programs (i.e., teaching, administrative service, grant proposal
preparation), the effort assigned to federally-sponsored projects should rarely
total more than 95%.
Summer Effort for Faculty with 9 Month Appointments
Faculty compensated for 9-month appointments are permitted to expend up to an
additional 3 months of summer effort on a combination of service (paid by the
College) and one or more sponsored programs in the period beyond the
academic year and earn up to 3 months of additional salary for that effort, subject
to sponsor policies and the approval of the department chair and dean.
A request for summer salary indicates a commitment to expend commensurate
effort on the particular project during the summer term (effort expended during
the academic year does not satisfy a commitment related to the receipt of
summer salary). Faculty who receive summer salary from sponsored programs
will be required to certify that the effort was expended on those projects during
the summer effort period.
Reporting Periods:
Every semester the effort distribution of each faculty member must be certified
through a Personnel Activity report (PAR), whether on paper or online. In order to
generate a PAR, staff effort notices must first be prepared and submitted by the
Principal Investigator and Grants Officer at the College to the RF’s Grants and
Contracts department. Staff Effort notices must be submitted to the RF within 90
days of the start of work on any sponsored award. Any staff effort notices
submitted after 90 days must be signed by the College’s Dean or Department
Chair with a letter of explanation attached and reviewed by the RF’s Chief
Financial Officer.
Online Effort Certification (PARs) is available to PIs the next working day after
the semester ends and will remain open for 45 days thereafter. For paper PARs,
after-the-fact certification must be signed and dated by the Principal Investigator
or Responsible Official at the College with first-hand knowledge and returned to
the RF within 45 days of semester end. Submission after 45 days requires a
letter of explanation and sign-off by the PI’s Dean or Department Chair.
The “after-the-fact” certification is done by semester using consistent periods for
all campuses. The spring period will include all activity from 01/16/XX –
5/31/XX, summer will include 6/01/XX – 8/31/XX, and fall will include
09/01/XX – 1/15/XX. Failure to submit PARs within the required time period will
result in a freezing of the College’s 9th Ledger Release Time Recovery account.
OMB Circular A-21 Effort Reporting Categories:
At the RF, the e-Release time system identifies effort related to sponsored
projects administered separately from all other effort. Sponsored projects
administered through the Research Foundation means all research and other
sponsored activities that are sponsored by federal and non-federal agencies and
organizations, separately budgeted and accounted for, and paid for by the
sponsor through the release time reimbursement or summer salary mechanism.
Definition of terms:
Organized Research means effort expended on all research activities of the
institution that are separately budgeted and accounted for.
Other Sponsored Activities is defined as effort expended on all programs and
projects financed by Federal and non-Federal agencies and organizations which
involve the performance of work other than instruction and organized research.
Examples of such programs and projects are health service projects and
community service programs. However, when any of these activities are
undertaken by the institution without outside support, they may be classified as
Other Institutional Activities.
Cost Share:
Cost sharing is that portion of the project’s cost not borne by the sponsor. The
federal government maintains the following 3 categories for describing cost
share:
1. Mandatory Cost Share – is required by the sponsor as a condition of
obtaining an award. When an award is received in which mandatory cost sharing
was proposed, the cost sharing becomes a binding commitment in which the
institution must provide and document as part of the award.
2. Voluntary Committed Cost Share – the sponsor does not require cost
sharing as a condition of the award however the institution offers cost sharing in
the proposal budget and it then becomes a binding commitment (voluntary
committed cost sharing) of the agreement, which the institution must provide and
document, as part of the performance of the sponsored agreement. A common
example of committed cost sharing is when a faculty member proposes a
percentage of their effort on the budget page, budget justification, or budget
narrative of their proposal which is submitted to the sponsor without any
corresponding request for funding by the sponsor.
Both Mandatory and Voluntary Committed Cost Sharing
must be:

Properly documented in the award;

Captured in the accounting system; and

Captured on the PAR.
3. Voluntary Uncommitted Cost Share (VUCS) – represents donated effort on
the part of College faculty including senior researchers to projects over and
above any formal binding commitment. This donated time is neither committed
to in the proposal or required by the award. Faculty are not required to
document voluntary uncommitted effort. It is not included in the organized
research base for F&A purposes. The value of uncommitted voluntary effort
cannot be used to meet the College’s cost sharing commitments.
Note: When the College reduces a faculty member’s level of activities
dedicated to other institutional responsibilities to shift effort to organized
research, the effort is not considered “donated” and the College must reflect
this effort separately as a line item budget called University Research in their
accounting system. University Research must also be certified on a PAR.
University Research is included in the research base for F&A purposes.
Salary Caps
Certain sponsors (e.g., NIH) impose a limit or “cap” on the annual rate of pay that
may be charged. The difference between the effort expended on the sponsored
program and the sponsor salary cap is designated as cost sharing. On summer
salary charges for faculty with 9-month appointments, the difference between the
base salary and salary cap need not be charged.