About This Policy

The official version of this information will only be maintained in an online format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material online prior to placing reliance on a dated printed version.

Effective Date: October 6, 2014

Revised: June 2020

Policy Statement

The Office of Management and Budget (OMB) Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards includes regulatory requirements for certifying effort expended on sponsored awards with which the University must comply. Effort directly charged to sponsored projects and any committed cost-shared effort (i.e., committed effort that is not directly charged to the award) must be identified in the University’s effort distribution/reporting system.

The principles that govern how the University must document time and effort on federal awards are included in the OMB Uniform Guidance, requiring each grantee to maintain a system of distributing salary charges to federal awards that results in a reasonable allocation of salary charges to each award. The salary distribution system also must include a periodic review to confirm the reasonableness of salary charges to the federal projects.

The University employs an after-the-fact effort reporting system that provides the principal means for certifying that the salaries charged to sponsored projects are reasonable and consistent with the portion of total professional activity committed to the projects.

OMB Uniform Guidance

Employee Categories

The following categories of University employees are certified on University-generated effort reports:

• All faculty, graduate students and administrative and professional employees with salary charged to sponsored projects
• All nonexempt support staff, undergraduate students and limited-duration employees paid on sponsored projects

University Position on Implementing Effort Reporting Policy

The University receives significant funding for sponsored projects from federal and state governments, private foundations, organizations and industry. There must be accurate effort planning and confirmation when these funds are expended for salaries and wages.

Effort certification is required by federal regulations for all compensation costs charged to federal sponsored awards. In order to be compliant with these regulations, the University is required to have a system in place for certifying the allocation of salaries and wages associated with sponsored projects.

The purpose of effort reporting is to provide a reasonable basis for distributing salary charges among direct activities (e.g., sponsored projects) and nonsponsored activities (such as instruction and administration). OMB Uniform Guidance requires that the University document the distribution of activity to each individual sponsored project, including any cost-shared effort (i.e., committed effort that is not directly charged to the award).

At the beginning of each fiscal and/or budget year, salaries and wages are planned and distributed to various activities based on an individual’s expected effort (i.e., effort commitment proposed in the sponsored project budget). Effort distributions should be reasonable estimates of activities, recognizing that research, instruction and clinical activity are often inextricably intertwined and estimates will be necessary in most cases. The tolerance level for effort estimations is within 5%. 

This effort distribution is normally accomplished by the department manager, in consultation with the PI.

The effort planning and confirmation system must only reflect the activity (research, teaching, administration and any other activity) for which the investigator or employee is compensated by the University. External activities such as consulting or non-University (professional) committees are not to be included.

The University is allowed to record effort as a percentage of total activities (i.e., teaching, research, administrative, including chairmanships and committee work, based on appointment or role at Brown University and compensated by Brown University), not as hours worked.   Therefore, all of an employee’s compensated activities must be reported in percentages of 100% regardless of the appointment full-time equivalent.

Changes in Effort

The effort distribution must be adjusted in a timely fashion for significant changes in effort when they become known. Changes in effort should be in alignment with the grant award agreement.  Effort changes that deviate from the agreed effort as established by the proposal should be within the parameters set by the sponsor in the agreement. For many federal awards, reductions in effort of greater than 25% require sponsor approval; therefore, sponsor terms should be reviewed before making this type of change. If you have any questions, please call Sponsored Projects for assistance.

Effort Certification vs. Labor Distribution

Effort certification and labor distributions are not the same thing.

Labor distribution (based on compensation) represents an initial estimate of how effort is expended and serves as a convenient document in support of activities on which the individual worked.

The effort certification process is a method for confirming that charges made to sponsored awards are reasonable in relation to the work performed. This is done by reviewing, updating and preparing salary reallocations and, if necessary, making appropriate changes to the effort reports, and certifying effort reports.

Individuals are not always paid from individual sources in direct proportion to the amount of activity provided to support that sponsor or account. If actual effort on a grant is greater than salary charged, and it is committed cost sharing, that cost shared effort must be captured on the Workday Effort Certification System via the use of designated funds.

Individual effort reports are required for all faculty, graduate students, administrative and professional employees, undergraduate students, nonexempt and limited-duration employees with effort allocated to sponsored projects.

An effort report for all faculty, graduate students and exempt employees is required to be completed semi-annually (January 1 to June 30) and (July 1 to December 31) in which a portion of their effort is allocated to a sponsored project.

An effort report for undergraduate students and nonexempt employees, who have all or a portion of their effort allocated to a sponsored project, is required to be completed on a quarterly basis (by pay period)

The effort report must represent, in percentages totaling 100%, a reasonable estimate of an employee’s University compensated effort for the period.

Verification and Sign-Off

All faculty certify their own effort except in limited circumstances. Exceptions to this practice require documented approval by the Director of Office of Sponsored Projects or their designee.  In addition, all student effort is certified by the Principal Investigator(s) on the assigned project(s) where the student’s effort is allocated.  For all other employees, Effort Certification Reports must be certified by the individual employee, or by a responsible supervisory official having firsthand knowledge of all the activities performed by the employee.

Proxies

All faculty, exempt and nonexempt workers are required to sign their own effort certifications semi-annually or monthly. Requests for proxies for these individuals will be granted only in extenuating circumstances and in cases where the proxy indicated has firsthand knowledge of the work performed on the project by the worker. Cost center managers (CCMs) or effort certification partners (ECPs) cannot be designated as proxies. 

Completed proxy request forms should be emailed to effort-reporting@brown.edu.

Request for Proxy of Authority for Effort Certifications [PDF]

Designees

All PIs are required to certify effort certifications for themselves and their students. In certain circumstances, the PI may delegate this responsibility to another individual with firsthand knowledge of their sponsored awards. The individual who signs the effort certifications must attest that the salaries charged and effort expended reasonably reflect work performed on the project and that the signer has sufficient technical knowledge and/or is in a position that provides for suitable means of verification that the work was performed. CCMs or ECPs cannot be assigned as designees. 

Completed designee request forms should be emailed to effort-reporting@brown.edu.

Request for Delegation of Authority for Effort Certifications [PDF]

Reporting Schedule and Deadlines

Semi-annual effort reports are generated in February and August, with certification deadlines in April and October.

Department Procedures

An individual, based on worker category, will complete effort certification monthly or semi-annually during each calendar year.

The schedule for certifying effort is determined at the beginning of each calendar year based on payroll cutoff period and does not change during the year. Sponsored Projects will provide advance notice to departments prior to running semi-annual effort reports.

It is recommended that department administrators develop an effort plan for each individual at the beginning of each fiscal year or grant budget period. Departments are responsible for periodically reviewing effort distribution for appropriateness and accuracy of effort expended on all projects. 

All costing allocations against grants and contracts should be reviewed to ensure alignment with effort commitments made in the award agreement. It is recommended that the review be done monthly or no less frequently than quarterly.

Reallocations

OMB Uniform Guidance requires adjustments to salary allocations (reallocations) in response to significant changes in work activity. Reallocations are considered cost transfers and must be in compliance with the University’s Cost Transfer Policy.

Failure to adjust salary allocations in a timely manner will result in errors to salary charges to grants, leading to over/under recovery of salaries. This is an audit exposure that risks Brown’s ability to receive external funding.

Effort Reporting Process

Effort Certification Reports are generated on the schedule assigned to the worker category and will route first to department administrators — CCMs or effort certification partners (ECPs). Automated email notifications from Workday provide an alert that effort reports have been generated for the period. CCMs and ECPs are to review the effort reports they receive for accuracy as soon as possible after the reports have been generated and routed to their Workday inbox. Based on the worker category, effort reports, once generated, will route to department administrators as follows:

• All effort reports for faculty, exempt and nonexempt workers and graduate students will route initially to ECP.
• All effort reports for undergraduate students will route to CCM.

During the review process and prior to certification by the worker, costed (reallocations of pay) or noncosted (administrative) changes can be made within the effort report to reflect unpaid committed effort, cost sharing, the NIH Salary Cap and/or to initiate a salary reallocation. In this case, the ECP/CCM changes the effort on the report via the “Change Effort” option on the report. Changes to the report require a reason for the change (Change Reason Code List) as well as an adjustment to the percentage effort allocated to the funding source. Regardless of the changes in distribution of effort, the total effort in an effort report must always equal 100%.

After the administrative review has been completed and any necessary changes have been made if applicable, the ECP/CCM submits the report to the appropriate worker who has been designated to certify the report.

The worker who certifies the report will review the effort report for accuracy. If the report is true to the certifier’s knowledge, the worker will select to certify and submit the report. If the report requires further editing because it is inconsistent with the actual effort expended, the certifier should return the report to the ECP/CCM with comments regarding the changes that are needed. The ECP/CCM will review the comments and make any necessary adjustments and return to the certifier for review and certification to complete the process. 

If costed changes (reallocations) have been made to the effort report during the certification process, a payroll accounting adjustment (PAA) will originate from the effort report after it has been certified such that the payroll information for the worker can be corrected in Workday to accurately reflect the information contained within the effort report.

Assigning Workers to ECPs

Workers are assigned according to their position within a given supervisory organization. A worker may not work on a grant that an ECP manages but may hold a position within the ECP’s supervisory organization and is therefore the respective ECP’s responsibility in the effort certification process.

Notifications and Reminders

When the Effort Certification Report is submitted (approved) by the ECP/CCM for certification, the certifier receives an automated notification. The certifier also receives an automated delinquency notification if the report is not certified by the due date.

Two days prior to the Effort Certification Report due date, a Workday generated alert is sent to the ECP. This alert will not be routed to the person who is the certifier.

Changing ECPs

To add a new ECP or to replace an ECP assigned to a department, send an email to the effort certification administrator (ECA) at effort-reporting@Brown.edu detailing the requested assignment. If the request is approved by the Director of Sponsored Projects or their designee, the ECA will submit a Workday ticket on behalf of the department. Completion of the assignment process usually takes between two to five business days.

Effort Funded by Other Grants

If an ECP needs to review an effort report for a worker who was funded by a grant managed outside their department, they should identify and contact the manager of the grant listed in the effort report, discuss the effort percentage(s) presented in the report that relate to their grant(s), and request that the grant manager verify the effort reported against their grant(s), preferably via email. 

Once effort has been affirmed, the ECP can upload the effort confirmation into the Effort Certification Report or document confirmation of the effort in the comments section of the report prior to submission of the report to the certifier.

Alternatively, if the ECP has identified the correct grant manager they may also delegate the electronic report to that individual. Delegation should be preceded by a conversation with the other grant manager to establish a clear understanding of what action needs to occur and the purpose of the delegation. If there are multiple grants on the effort report, and one or more of them belongs to the ECP’s department, comments should be added to the effort report to attest to the accuracy of the effort on their area’s grant(s) prior to delegation to an outside department.

If the ECP cannot identify the correct grant manager by the grant number, they may contact Sponsored Projects.

Manual Effort Certification

In some cases, it isn’t possible to complete certification electronically. In these instances, the ECA will send a manual certification template to the ECP/CCM) upon request or as a result of receipt of a terminating worker notification. These forms must be completed and certified by the appropriate party as outlined in the effort certification policy. Once the ECP returns the certified form to Sponsored Projects, the ECA can upload the forms into the electronic report so that the effort is still recorded electronically in Workday. 

Email effort-reporting@brown.edu for the forms for the relevant periods that require manual certification.

Effort Report Re-Certifications

Once an effort report has been certified in Workday, no further adjustments to that individual’s distribution of effort are allowed unless approved by the Director of Sponsored Projects or their designee. Changes to previously certified effort erode the credibility of the certifier as well as the entire effort certification process.

Changes to a certified effort form (re-certifications) are not allowed except in limited circumstances. Sufficient documentation must be provided that supports allowability and allocability and must explain why the effort was originally certified incorrectly. An effort re-certification requires the approval of the Director of Sponsored Projects or their designee.

Terminating a Worker

If a grant-funded worker subject to effort reporting is scheduled to terminate from the University, the department administrator should ensure that the worker is terminated in advance in Workday as soon as possible prior to the worker’s actual departure date from the University.   Termination in advance originates business processes in Workday that will notify Sponsored Projects of the grant-funded worker’s pending departure, initiates production of the effort reports that need to be certified for the worker’s effort through the termination date, and affords the opportunity for workers who certify their own effort to certify electronically or manually prior to leaving the University. 

Termination notifications received after the worker’s departure initiate a primarily manual certification process in which effort certification forms must be certified by the PI or other individual with firsthand knowledge of the work performed from a supervisory perspective because the worker is no longer available to certify. In this case, a manual form is provided to the department administrator by Sponsored Projects, which must be completed, certified by the appropriate party and returned to Sponsored Projects. The manual certification process can be more time intensive; therefore, the recommended approach is termination in advance as previously outlined.

Sponsored Projects is responsible for the electronic distribution, collection and retention of all effort reports. Individually reported data will be made available by Sponsored Projects to authorized auditors.

Effort Certification Reports are to be certified by the PI or worker within 30 days of being generated by the Sponsored Projects. 

To ensure timeliness of certifications by workers in compliance with University guidelines, department administrators should utilize the Workday Effort Certification Summary Report to proactively manage the effort reporting process within their area. This report should be reviewed on a weekly basis to determine what reports may still be outstanding in the department and in need of certification by the certifier. Administrators should continue to follow up with certifiers who remain on the report in an “in progress” status as the respective effort reporting deadline approaches in order to facilitate resolution of such reports.

Extensions

The University understands there may be exceptional circumstances that will warrant an extension. If an extension is needed, the reason for the extension must be documented and approved by the Director of Sponsored Projects or their designee, in advance of the report deadline.

Be advised that excessive disregard of the policy could lead to disallowed costs on sponsored projects, which could then be transferred by Sponsored Projects to a departmental account.

Completed extension request forms should be emailed to effort-reporting@brown.edu.

Request for Extension for Effort Certifications (PDF)

Record-Keeping Requirement

All Electronic Certification Reports are kept online within the Workday Effort Certification System, which is the official system of record at Brown University.  Therefore all reports are discoverable documents by both internal and external auditors.

First Delinquency Notification

The first business day following the due date, the first delinquency notification process begins.

A delinquency memo generated by Workday will burst to the certifiers, ECPs or CCMs who need to take action on an effort report to remind them that the report is overdue and request completion of the assignment. In the following 15 days after the due date, Sponsored Projects will follow up with an email reminder to the certifier/approver and copy the ECP/CCM regarding any past due effort reports.

Second Delinquency Notification

If 30 business days have passed since the first delinquent notification was sent, and the delinquent effort certification report has not been certified, and there has been no approved extension request on file nor has a follow-up been made by the department to Sponsored Projects, a second delinquency notification will be sent.

The second delinquency notification will be in the form of an official delinquency letter from the Director of Sponsored Projects or their designee and the Associate Vice President of Research, and is sent to the department chair/director, with a copy to the department administrator.

Department chairs and PIs and/or persons responsible for certification shall be made aware of the audit risk as a result of noncompliance with University policy.

The effort certification requirement to document compensation costs charged to federal sponsored projects (2 C.F.R. § 200.430(i)(1)) must continue to be adhered to during a time of alternative work and learning arrangements. Documentation supporting all effort on sponsored projects must continue to be maintained for all faculty, graduate and undergraduate students, administrative and professional employees, and exempt and nonexempt employees. 

In response to University emergency/remote work orders, the following short-term administrative flexibilities to the effort reporting policy have been adopted for periods impacted by the emergency/remote work order:

• Effort reports for undergraduate and nonexempt employees will be completed on a quarterly basis for the prior 90 day period, rather than on a monthly basis to assist Effort Certification Partners manage the administrative burden.
• A 30-day extension will be granted for effort reports impacted by the remote work order period.

Awarded/Committed Effort​

Awarded or committed effort is the amount of effort (in percentage [%]) promised by the University in the proposal budget or the awarded effort (in percentage [%]) included in award documentation.

Cost Sharing

Cost sharing is a portion of total sponsored project/program costs not funded by the sponsor. 

Cost Shared Effort

Cost shared effort is a commitment of Brown University’s resources/funding that supplements externally sponsored projects. This occurs when actual committed effort exceeds the salary charged to a project. Committed cost share must be properly documented and tracked.

Committed Cost Sharing of Effort

Committed cost sharing of effort is required by the sponsor, identified or quantified in the proposal and a condition of receiving the award. It represents binding commitments that must be captured and documented and must be certified.

Designee

A designee is another individual (other than the principal investigator, or PI) who has been delegated and authorized to carry out certification responsibilities on a sponsored project for effort certification.

Effort

Effort is the proportion of time spent on activities related to a PI’s or employee’s duties, for which University compensation is received. Total effort must always equal 100%. External activities such as consulting are not included.

Effort Certification

Effort certification is the process by which the employee asserts in writing the correctness of employee percentage (%) of effort.

Effort Certification Partner

An effort certification partner (ECP) is an administrator assigned to oversee the fulfillment of effort certification requirements for a supervisory organization within the University. 

Effort Reporting

Effort reporting is the mechanism used to provide assurance to federal or other external sponsors that salaries charged or cost shared to sponsored awards are reasonable in relation to the work performed. Effort reports are referred to as “certifications.”

Payroll Distribution

Payroll distributions and effort reports are not the same thing. Payroll distributions are the distribution of an individual’s salary, while effort reports describe the allocation of an individual’s actual time and effort spent on specific projects, whether or not reimbursed by the sponsor. Payroll can be expressed as an estimate of actual time worked and is the basis for generating the effort statement.

Institutional Base Salary

Institutional base salary is the academic-year salary as well as any stipend received for performing other administrative duties, whether as a center director, department chair or program director.

It does not include payments for bonuses, one-time payments, overtime or incentive pay. It also does not include income earned for work performed outside of University responsibilities. Institutional research funds taken in lieu of compensation are not included in the calculation of IBS. 

Because administrative appointments are made on an annual basis, the stipend is considered compensation for responsibilities executed throughout the full year; by contrast, compensation for academic appointments is for work done during the nine-month, 10-month or 12-month academic year.

When charging a portion of monthly effort to research grants, a monthly salary should be computed as one-ninth of the academic-year salary (or one-tenth, for 10-month appointments) plus one-twelfth of the administrative stipend.

Labor Distribution

Labor distribution is an allocation of one’s efforts to specific general ledger accounts. The general ledger documents effort in the University’s books and records. Note: Labor distribution requires a conversion of time (i.e., effort) to dollars (i.e., compensation).

Proposed Effort

Proposed effort is the amount of effort (in percentage [%]) in any sponsored project application, regardless of whether salary support is requested.

Proxy

A proxy is an individual delegated and authorized to carry out certification responsibilities for the PI/faculty member’s individual effort certification.

The major responsibilities each party has in connection with the University’s Effort Reporting Policy are as follows:

Effort Certification Partner (ECP) and Cost Center Manager (CCM)

• Reviews, changes (if necessary) and submits electronic Effort Certification Reports
• Establishes effective processes and controls to ensure compliance with this policy
• Ensures accurate planning and confirmation of effort, including cost sharing
• Oversees the effort planning and confirmation process. 
• Ensures payroll is in line with certified effort by completing salary reallocations, updating Workday with a worker’s costing information and documenting cost sharing
• Actively tracks certification progress each effort reporting period and follows up directly with certifiers to ensure completion

Effort Report Training

Formal training for ECPs and CCMs is offered twice yearly, typically in the summer and the fall.  Check for training opportunities in Workday Learning. ECPs and CCMs provide guidance to certifiers within their departments based upon their training.

PI and Workers

• Ensures appropriateness and accuracy of effort expended on sponsored projects
• Provides updates to effort distributions, as changes become known
• Reviews, sends back (if necessary) and certifies effort reports
• Requests sponsor approval for any effort reductions of 25% or more, paid or unpaid, on a federal grant or contract (If the PI or key personnel reduce paid effort, they may choose to document cost sharing so that the total effort does not decrease.)

Sponsored Projects

• Develops and implements effort reporting policies, procedures and training in accordance with the regulations set forth in OMB Uniform Guidance
• Develops and delivers appropriate effort reporting training sessions.
• Electronically generates and distributes effort certification reports for all employees identified as expending effort on sponsored projects
• Reconciles costed changes made to effort certification reports to Payroll (adjustments)
• Monitors the effort planning and confirmation process to ensure compliance with the University’s Effort Reporting Policy
• Reviews effort reports to ensure reports are reviewed and accurately completed and returned to Sponsored Projects on a timely basis.
• Reports questionable practices and recurring problems to the Associate Vice President for Research and the Director of Internal Audit
• Works with external auditors as they monitor the University’s compliance with effort  reporting regulations

Internal Audit

• Independently evaluates compliance with effort reporting requirements

NIH Salary Cap

Certain sponsors impose a limit or “cap” on the annual rate of salary reimbursement.   Nevertheless, investigators must still devote the full committed effort as proposed and awarded without regard to the salary reimbursement limitation.

Effort reports for individuals earning in excess of the capped amount must reflect the difference between the cap and the actual salary. View Brown’s National Institutes of Health (NIH) Salary Cap Policy for specific guidelines developed for calculating and reporting that effort.

Salary Cap Examples

If the cap is $175,700 annually and the individual spends 50% effort on the project during the spring, the maximum salary that can be charged to the project during the semester is $43,925 (50% x $175,700 / 2).

Cap cost sharing must be reflected on the effort report. When the salary is greater than the cap, effort will be greater than the pay distribution on the effort report for that award.

For example, assume the cap is $175,700, salary is $195,000, committed effort is 47% and actual effort is 50%: Salary to be paid from the award = 42%; the effort report will only show the 42% effort charged to the award. Cost-shared salary = 5%; this effort needs to be documented  and certified.

• NIH Salary Cap Policy
• NIH Salary Cap Summary

Committed Cost Sharing (Mandatory and Voluntary)

Committed cost sharing must be captured and documented as outlined in Brown’s Cost Sharing Policy. Where the project sponsor pays for some or all effort an individual has clearly committed to, that effort must be reported as unfunded activity (cost sharing). Committed cost sharing is tracked via the Workday Effort Reporting system and captured through the use of designated funds.

• Cost Sharing Policy
• Cost Transfer Policy