Effort Reporting Policy Case Western Reserve University
Statement
Case Western Reserve University (Case) requires all faculty
who work on sponsored projects to verify that the time
they have reported and charged to these sponsored projects
is accurate. This time will be reported as a percentage
of the overall faculty effort, which encompasses all of
the activities assigned to the position. The time of the
research staff reported and charged on sponsored projects
will be certified by the principal investigators.
Applicability
This policy applies to all individuals with roles on
Case-administered sponsored projects, whether the primary
appointment of the individual is established through the
University or through one of its affiliated hospitals.
Definitions
Effort is defined as the total scope of responsibilities
expected of the appointment, regardless of the actual
number of hours worked. Expectations of the position are
generally established as part of the appointment process.
The effort report is the means by which an individual
documents the proportion of time allocated to each of
the activities with which s/he is involved. This becomes
the official verification that the salaries charged to
sponsored projects are consistent with the reported effort.
Cost-sharing occurs when the University bears a portion
of the costs of a sponsored project (e.g.,committing personnel
at no cost to the project.) Mandatory cost share is required
by the sponsor as a condition of award. Voluntary cost
share is not required by the sponsor but may be pledged
in a proposal budget or budget justification. If the budget
is so approved, the cost-sharing becomes mandatory,
Purpose and Reason
Effort reporting is a federal requirement. As a recipient
of federal funds, the University requires certification
of effort to provide a reasonable basis for distributing
salary charges among direct activities (e.g., sponsored
projects, instruction, clinical activity, and administration.)
Other government and private sponsors provide significant
funding to the University, and the effort reporting system
assures these sponsors that salaries and wages are properly
expended and consistent with the effort devoted to the
projects they have sponsored. All faculty and staff involved
in certifying effort must be aware that severe penalties
and funding disallowances may result from inaccurate,
incomplete, or untimely effort reporting.
Guidelines and Expectations
Activities to be used as the base for calculating percentages
of effort should include all research, teaching, administration,
clinical responsibilities, and any other activity that
has been established as being within the scope of responsibility
for the Case and/or affiliated hospital appointment, regardless
of the source(s) of compensation for this set of activities.
These responsibilities will normally be defined as part
of the appointment process.
The compensation base that is used in related documents,
such as grant proposals, should be the compensation that
is established for the defined set of activities of the
appointment, and does not include independent consulting
performed outside of the parameters of the appointment,
nor should it include incentives or bonuses received for
clinical performance.
Frequently Asked Questions
Effort is the proportion of time spent on professional
activities such as research, teaching, administration,
service for which an individual is employed by Case or
for which one is appointed as a Case faculty member.
For clinical faculty at the Case School of Medicine, effort
also includes clinical activity for which they receive
compensation from Case or a clinical practice plan or
other source of compensation for clinical activity.
Effort does not include activities such as consulting
that are conducted outside the terms of employment at
Case or outside a Case faculty appointment.
1. What is Effort Reporting?
Effort reporting is a method of documenting the proportion
of work time devoted to these professional activities
as a percentage of total professional activity. It is
important to note that effort is not calculated on a 40-hour
workweek. If an individual normally works 80 hours in
a week, 40 hours represents 50% effort. Total professional
activity is not measured in a specific or defined number
of hours.
Payroll and effort distributions are not the same thing.
Payroll distributions describe the allocation of an individual
salary, while effort distributions describe the allocation
of an individual’s activity to individual projects
“independent of salary”. The two reports are
related, but an individual’s effort reporting requirement
cannot necessarily be derived from a salary distribution
report.
Case’s effort reporting process relies on payroll
distributions to provide a general reminder of the projects
on which an individual’s salary was charged during
the certification period. Individuals completing effort
reports are required to identify other areas where they
provided effort with partial or no Case salary support
and to ultimately report the appropriate distribution
of effort over all activities.
2. Why is Effort Reporting Important?
As a recipient of significant sponsored funds, Case must
assure federal and other sponsors that the assignment
of effort and associated salary and fringe benefit costs
to projects they sponsor is fair, consistent, and timely.
The Effort Certification Form is the document that Case
utilizes to confirm effort on externally sponsored projects.
Signed Effort Certification Forms are considered legal
documents in which an individual attests to the accuracy
of the effort spent on sponsored projects. Material inaccuracies
in Effort Certification Forms can result in the misallocation
of costs to sponsored projects. An improper allocation
of costs reported by internal, external or federal auditors
may result in substantial restrictions in ongoing research
activities and can affect Case and the individual researcher
both financially and publicly.
3. Who is subject to Effort Reporting?
Every individual who devotes effort to sponsored activities,
whether this effort is paid or unpaid, is subject to effort
reporting.
4. What is 100% effort?
The total amount of effort expended to accomplish the
professional activities of Case faculty, staff, and students
regardless of the actual number of hours expended on those
activities. This normally includes all effort expended
on Case-compensated sponsored research, administration,
teaching, unsponsored scholarly activity, and other activity
and, in the case of clinical faculty, clinical activity
compensated by clinical practice plans. 100 per cent effort
is not defined as a single, standard number of hours or
days per week, since it will likely be different for each
person and may vary during the year. The number of hours
implicit in an individual’s 100% effort must be
reasonable and supportable to department, school, university
and external reviewers, if requested. In most circumstances,
a minimum of 40 hours (assuming a full-time schedule)
and a maximum of 80 hours would be considered a reasonable
average work week.
5. Can the total effort listed on the Effort
Certification Form be less than or greater than 100%?
No. The effort percentages on the Effort Certification
Form must total 100% - neither more or less. All Case
compensated effort (and for clinical faculty, Case compensated
effort and hospital or practice plan compensated effort)
must be accounted for; and obviously the sum of the individual
effort categories cannot be greater than 100%. Again,
just because an individual may work more than a normal
35- or 40-hour week does not alter this rule. For example,
an individual who spends 40 hours a week on sponsored
research and 40 hours a week on clinical activity would
report an effort percentage of 50 percent for each category,
totaling 100 percent for the report period.
6. Are there some sponsored projects where I
can report 0% effort?
Individuals are expected to commit some level of effort
(>0%) on sponsored projects on which they are listed
as a principal investigator or key personnel. Exceptions
to this guideline are equipment and instrumentation grants,
doctoral dissertation grants, student supplement grants,
and institutional/individual training grants (for faculty
mentors).
7. Who should sign the Effort Certification
Form?
The person completing and signing the Effort Certification
Form must be someone with first-hand knowledge of the
effort expended. This is required to ensure that the effort
reporting system reasonably reflects actual effort expended
in the various categories during the report period. In
general, this is the individual whose effort is being
reported. At Case, faculty on sponsored projects will
certify their own effort. Non-faculty key and other personnel
(including graduate students, post-doctoral fellows, research
assistants) will have their effort certified by the principal
investigator of the sponsored project to which they are
contributing effort.
8. How often are Effort Certification Forms
completed?
For schools or colleges within the university that provide
faculty with 12-month appointments, Effort Certification
Forms are completed semi-annually, based on the fiscal
year. The Form for the period from July 1 to December
31 is completed in January of every year. The Form for
the period of January 1 through June 30 is completed in
July of every year.
For schools or colleges that provide faculty with academic
year (or 9-month appointments), Effort Certification Forms
are completed three times a year, i.e., in the month following
the end of fall semester, in the month following the end
of spring semester, and in the month following the end
of summer semester.
9. What if my effort on an externally sponsored
project changes during the reporting period?
If the change in effort during the reporting period is
one that needs to be reported to the sponsor (e.g., NIH
requires a reduction in effort of 25% or more to be reported),
this report must be submitted to the sponsor. The faculty
member may revise his/her effort report for Case at the
same time, or at the time of the semi-annual certification.
If the effort change is not enough to meet the external
agency’s reporting requirement, the change may be
entered at the time that effort is certified for Case.
However, adjustments to payroll must be made promptly
if the effort change results in salary distribution changes.
10. What if I make a mistake on my effort certification?
May I go back and correct it?
Faculty are required to review, modify as necessary,
and certify that the effort percentages for themselves
and their key personnel are reasonable estimates of the
actual work performed. Federal guidelines and Case policy
recognize that the activities that constitute effort are
often difficult to separate. Effort certification must
often rely on a reasonable estimate of effort, and when
estimating, a degree of tolerance is appropriate. However,
a change in effort noted on the effort certification form
(regardless of how small the change is) must always be
accompanied by a change in the payroll or cost sharing.
Certified effort forms assert that the information represented
is to the best of the certifier’s knowledge, accurate
and complete. Changes to previously certified effort erode
the credibility of the certifier as well as the entire
effort certification process. For these reasons, changes
to a certified effort form are not allowed except in limited
circumstances, which require extensive documentation as
to why the effort was originally certified incorrectly.
Likewise, it is important for administrators to complete
known salary distribution corrections and salary transfers
before the effort form is certified, so that records are
consistent. Retroactive changes to payroll distribution
that contradict certified effort are not allowed after
certification.
11. What specific activities fall into the categories
of teaching, clinical service and administrative activities?
What if these overlap with research responsibilities?
Effort devoted to instruction should be reported in a
separate category from research if it involves classroom
teaching; e.g., medical student lectures or graduate student
courses. Mentoring a graduate student in the laboratory
is closely intertwined with research and the respective
allocations of effort must be estimated.
Clinical service encompasses patient care activities.
However, time spent in clinical activities may also be
attributable to research (e.g., recruiting patients to
trials, following up on research protocol related matters)
as well as teaching if students and residents are rotating
on the service. This overlap is accepted and differentiation
among activities is not expected to be precise. It is
understood that the distribution of effort will be an
estimate.
12. Can you give me some examples of cost-sharing?
If personnel devote some effort to a sponsored project
and are not paid for that effort from the project, that
effort is shown in the cost-sharing column on the report
form and the salary that is supported by other sources
is reported as cost-sharing. Likewise, if an individual
on a Federally-sponsored project has an institutional
base salary that is greater than the Federally-mandated
salary cap ($180,100 in 2005), the portion of salary and
effort over the cap must be shown and captured as cost-sharing.
13. How do I report cost-sharing of effort?
The Effort Certification Form requires that effort expended
on an activity be reported, whether or not that activity
is funded by an outside source. For example, if a faculty
member expends effort on a sponsored research project
but does not charge the project for all (or any) of his
or her salary for that effort, the entire effort must
still be allocated to that project. The unfunded effort
is generally considered cost sharing and must be recorded
in the cost-sharing column next to the listing of the
specific sponsored research project on the Effort Certification
Form. As an example, if a faculty member expends 75% of
his or her total effort on a sponsored project, but the
sponsor is charged for only 50% of his or her salary,
the 50% is entered on the Effort Certification Form in
the column marked “Direct Charge” and the
25% is entered in the column marked “Cost-sharing”.
It is important to understand that this rule applies only
to effort expended on a specific sponsored project.
14. How long should departmental copies of Effort
Certification Forms be kept?
Grants Accounting is responsible for retaining the signed/certified
Effort Certification Forms (either hardcopy or electronically
signed versions), based on federal record retention guidelines.
Grants Accounting strongly recommends that departments
retain signed/certified Effort Certification Forms for
a period of three years from the close-out of the project.
15. What kind of documentation or supporting
evidence is needed as back-up to the Effort Certification
Form?
This can vary as a function of the individual and department
and whether they are engaged in activities other than
externally sponsored research conducted through Case.
Examples of the types of documentation that could support
the Effort Certification Form include the faculty activity
summaries, payroll records, clinic schedules, personal
schedules, consult schedules, or class schedules. These
supporting documents should be kept for a period of three
years from the close-out of the project (i.e., for as
long as the Effort Certification Form is kept). Return
to top
16. Is training available for effort reporting?
Yes, formal workshops and seminars about Case’s
effort reporting system are provided throughout the academic
year. In addition, individuals knowledgeable about Case’s
effort reporting policies and procedures are available
to assist on an as needed basis. For faculty in the School
of Medicine, the Office of Research Administration provides
assistance. Contact Narinder Dhaliwal (Narinder.Dhaliwal@case.edu,
368-2001).
17. I have a part-time VA appointment and my laboratory
is located there. How do I complete the effort report?
The Memorandum of Understanding between the VA and the
University that is completed and certified for you should
serve as the basis for your effort report.
18. A faculty member serves on the IACUC at
Case. Is this considered part of the faculty appointment?
Yes, this is considered part of the Case appointment.
Participation on committees and boards of the University
would be counted in administrative or service responsibilities.
19. A faculty member represents the University
on a review committee for a granting agency, and receives
an honorarium for this service. Is this counted toward
institutional effort?
These responsibilities are not normally considered part
of the faculty appointment at the University, and therefore
are not considered during the effort reporting process.
20. A researcher in a clinical department receives
partial salary support from faculty practice plan income.
Does this create a problem in the effort report, since
the faculty member does not have any clinical responsibilities?
Practice plan income may be used to support activities
in addition to clinical service. In this case, the department
is supporting a faculty member whose primary responsibility
is research, and there is no inherent problem with this
situation.
Salary and effort distribution are two separate but related
issues. The first step in the effort reporting process
is to determine the distribution of effort. If clinical
income is used to support research activities, this will
be shown as a source of cost sharing for the research
activity, since the faculty member does not have clinical
responsibilities.
Power
Point Presentation
Federal
Regulatory Document for Effort Reporting (OMB A-21, Section
J(8))
Contact Information:
Richard J. Sohn, MBA, PhD
Associate Dean for Research Administration
Richard.sohn@case.edu
368-4432
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