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Effort Certification

Frequently Asked Questions

Effort has to be certified for all faculty and professional staff, including temporary instructors, graduate assistants, and temporary professional employees, who, during the period to be certified, receive some portion of their compensation from, or who contribute effort to, a sponsored program, restricted fund or University cost share.

The effort of all classified employees, including students, temporary employees, and graduate assistants paid on a bi-weekly basis, assigned/appointed to sponsored programs or assigned/appointed to positions for the purpose of fulfilling the University's obligation to sponsored program (cost-sharing), will be certified in conjunction with time reporting.

A key concept is that hours are not certified, effort is. 100% effort encompasses the total amount of time spent by a faculty or staff member to perform all of the activities required by his or her job with the University.

Effort is not based on a 40-hour week.

Individuals are required to certify 100% of their compensated effort of their base salary.

Effort does not include summer pay or extra compensation payments.

Faculty members must account not only for their sponsored program and training effort (whether sponsor paid or cost shared), but also their instruction/administrative effort (including nonsponsored personal research, scholarship, and artistic endeavors as well as classroom teaching) and their service to the University on committees, etc.

Typically, graduate assistants have only 50% appointments. However, that 50% appointment constitutes their entire “job” with the University and therefore represents 100% of their compensated effort. Hence, their effort reports will show 100%.

Salaries and wages typically comprise the majority of direct costs charged to sponsored projects, therefore it is important to verify that salary and wage charges are appropriate. Appropriately certified effort reports provide auditable documentation to demonstrate to sponsors that they received the level of effort described and expected through the proposal process, the award process, and all post award communications with the sponsor. Both direct and indirect costs may be disallowed and penalties imposed after reimbursement if auditors find such documentation to be inadequate. In addition, criminal charges may be brought against the individual certifying falsified effort.

The following areas are receiving significant attention nationally:

• 100% research faculty - are they involved in activities that should be funded by sources other than their grants?
• Faculty with 5 or more federal awards - are they overcommitted? Are the percentages of salary distributed to each of their projects reasonable?
• Change in Level of Effort - are faculty seeking permission to change the level of effort proposed in their grant when required (typically when the change is 25% or more)?
• Faculty with less than 5% of their effort on many awards - are they contributing the effort promised?
• Faculty Effort Certification - is it timely?
• Retroactive Salary Cost Transfers - are they infrequent, but timely when necessary? Of particular concern are those affecting time periods for which faculty have already certified their effort.
• Total effort commitments (paid and cost shared) to the sponsor - are they met?
• University effort reporting policy - is it being followed?

All faculty and professional staff, including temporary instructors, graduate assistants, and temporary professional employees, who are paid by a sponsored program contract, grant, restricted fund or University cost share must certify effort for regular pay as part of the Effort Certification process.

Following certification, the Principal Investigator (PI) must review and confirm that the salary charged and effort committed is reasonable in relation to actual effort spent.

Additionally, sponsored projects are not limited to federal funds as the University applies the same standards for fiscal accountability to both federal and non-federal (state, local, etc.) sponsored projects.

If the faculty member or employee is not available to certify their effort, it is critical that a person with first-hand knowledge of all of an employee’s effort or have suitable means of verifying that work was performed certify for the employee.

While the effort certification process suggests a high degree of precision, there is an acknowledgement that this is impossible and that the process is based on estimates. The federal regulation states:

"It is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate."

The timeline for distribution and completion of the reports by the certifier is as follows:

9 Month Faculty and 8/9 Month Graduate Assistants with Sponsored Activity

12 Month Faculty, Administrators, 12 Month Graduate Assistants with Sponsored Activity

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.

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.

Detailed process maps for Certifiers (faculty, GAs, researchers working on a sponsored program) and for Principal Investigators are available online at "http://bf.memphis.edu/finance/accounting/effort.php.

Please contact the Business Officer of the appropriate college or unit for help: