Sponsored Programs and Research
Effort Certification on Externally Funded Programs
This policy sets forth the University’s standard for certification of effort expended on externally funded program awards (grants) administered by the University. For purposes of this policy, the term “sponsored programs” means a program that is externally funded. This policy applies to all individuals who commit and devote effort to a sponsored project as well as those individuals involved in certifying the effort of individuals on a sponsored project.
The intent of this policy is to ensure that University practices are in compliance with Federal regulations in OMB Circular A21, Part J(10).
Under this policy, all University employees devoting a portion or all of their effort on sponsored projects will be required to certify the percentage of such effort that was expended on the project. This certification will be after-the-fact documentation as follows:
- Exempt Employees and Graduate Assistants: The University will implement an after-the-fact confirmation system certifying that labor allocations between sponsored agreements, other direct programs not part of the grant, and institutional support activities are both accurately reported and certified by the employee or the employee’s supervisor. The Effort Certification Program within Banner will be utilized for this purpose and will be certified on a monthly basis. [Cir A21-J(10)(2)(b)]
- Non-Exempt Employees: Payroll time records completed by non-exempt employees will be used as after-the-fact documentation to support the effort of non-exempt employees with wages allocable to sponsored agreements. The Payroll Time Records will be completed for each bi-monthly pay period. [Cir A21-J(10)(2)(f)]
- Supplemental or Incidental pay for services performed outside of the employee’s normal work schedule will not require effort certification, on the condition that the payment is separately identified and documented in the Banner system.[Cir A21-J(10)(a)]
The administration of the effort certification process will be the responsibility of the following offices:
- Sponsored Programs and Research (SPAR) – The SPAR Office will be responsible for the maintenance of the Effort Certification process in the Banner System. This will include the responsibility for generation of the effort reports for Exempt employees, including Graduate Assistants, and monitoring the process to ensure all effort is certified. Effort certification reports will be generated monthly. The Effort Certification report will be certified by the employee; and if the employee is not available to perform the certification, the employee’s supervisor or other official with direct knowledge of the employee’s effort will perform the certification.
- Payroll Office – Hours worked are entered into the Banner time record by the employee or the employee’s immediate supervisor and will document hours worked on grants. This document also indicates the Banner Fund/Org that is being charged for the hours and is verifiable by the employee and supervisor. The time record will be used by the Payroll Office to generate the payroll for non-exempt employees on a bi-monthly basis.
- Human Resources – The Electronic Personnel Action Form (ePAF) submitted by the hiring department will serve as documentation of incidental and supplemental payments. An ePAF must be completed solely for the purpose of incidental or supplemental payment, and may not be combined with other transactions. HR will enter the payment information into the Banner system according to the information provided in the ePAF.
- Departmental Grant Administrators and Principal Investigators are responsible for ensuring that all payroll charges reflected on their grant accounts are appropriate and accurate.
Internal Control Considerations
Internal controls within the effort certification process are enforced by separation of duties and existing controls within the finance system for initiation and generation of the payroll. All project accounts are separately recorded in the University finance system, providing an effective means of tracking actual expenditures to source documents.
Sponsored Programs and Research; Prior Date of Review: July 2015