Bi-Weekly Labor Report (BLR): BLR is the official UAH timesheet used to record effort for exempt employees (to include faculty). The Web Time Entry form is used to record hours worked for non-exempt and on-call employees. Both types of records should be entered online through Self-Service. The BLR distribution is entered by the department/center through ePAF Labor.
Certification: Legally binding event on the employee and UAH, whether via paper or electronic signature.
Committed Cost Sharing: Effort (or other cost, including voluntary cost sharing) not required by the sponsor, but proposed in the sponsored project proposal budget or budget justification with no corresponding funding requested or awarded. When this type of cost sharing is offered and the sponsored project is awarded, the cost share is required.
Effort: The proportion of total professional effort devoted to a specific function or project expressed as a percentage of the total professional effort. Total effort must equal 100%.
Effort Commitment: The portion of time committed to a particular activity expressed as a percentage of the individual’s total activity for the institution. The commitment, stated as a percentage of an individual’s time in a contract or grant proposal, is a real and binding commitment. As long as the contract/grant is active, the individual must keep track of the effort commitment and is required to account for it.
Effort Certification (also known as an Effort Report): A form that must be certified by all university employees charging to a sponsored award to verify that the salary distribution across all activities is consistent with the actual portion of total professional effort committed to each function. The effort certification process is also important because it: (a) ensures the funding agencies that effort funded is related to the sponsored project; (b) is used to develop the Facilities and Administration (F&A) rate agreement; (c) is used in a number of management reports; and (d) documents labor cost sharing on sponsored projects. Effort Certification will be in accordance with Appendix 2.
Effort Reporting: The mechanism used to confirm that salaries and wages charged to each sponsored agreement are reasonable in relation to the actual work performed. Certification of an Effort Report must reasonably reflect the activity for which the employee is compensated by the institution. Cost sharing commitments must also be confirmed through the effort reporting mechanism.
Full Workload: Includes instruction, research, public service, and administration. UAH policy is that 20% (i.e., a three-hour course load) of this time is available for faculty research, and 5% is generally assigned for administrative duties. Activities excluded are outside professional work, volunteer community work, services on peer review panels and other advisory activities for sponsors and leadership in professional organizations. Note: the use of a 40-hour work week for salaried faculty and staff is a violation of the cost principles defined in OMB Circular A21 (relocated to 2 C.F.R. Part 220) and Uniform Guidance 200.430, when defining a full workload.
Institutional Base Salary (IBS): The annual compensation paid by an organization for a salaried employee’s appointment, whether that individual’s time is spent on research, teaching, or other activities. All salary charged to sponsored research contracts and grants will be based on the individual institutional based salary, and Intra-University (Across Department) Consulting. IBS excludes any income that an individual is permitted to earn outside of duties for the applicant/grantee organization.
Mandatory Cost Sharing: Cost sharing required as a condition of an award or agreed to between the institution and the sponsor when negotiating a sponsored agreement. When this type of cost sharing is offered and the sponsored project is awarded, the cost sharing is required.
No-Cost Extension: A no-cost extension could be necessary when a project period has reached its end date, but effort toward the project may still be required. In these situations, PIs or other key personnel may continue contributing the original committed effort, or they may reduce effort upon agreement with the sponsoring agency. Regardless of the agreement with the agency, this effort may be unfunded and require institutional funds to support the individual. Unfunded effort during a no-cost extension is a form of cost sharing.
Responsible Person: OMB Circular A-21 (relocated to 2 C.F.R. Part 220) identifies a responsible person as someone with suitable means of verification that the work was performed. A responsible person must certify employee Effort Reports.
Total Professional Effort: All activities conducted under the UAH terms of employment. This includes time devoted to research, teaching, administration, and other related activities. Total professional effort must always equal 100% regardless of the actual number of hours worked by an employee or the appointed time base. For example, if employee A works 80 hours per week to fulfill her responsibilities to the university and employee B works 40 hours per week to fulfill his, each employee’s total professional effort is 100% despite the fact that employee A worked twice as many hours as employee B.
Total Period Compensation: Total salaries/wages paid for a specific period (e.g., fall semester, summer session, etc.) under the terms of employment at UAH.
What Is the Difference between Effort Commitment & Effort Reporting: Effort Commitment is that effort committed or promised prior to or at the start of the project. It is not the actual effort expended, but a projected amount. The amount committed should be a realistic amount that can be adhered to. Effort Commitment is tracked by the Office of Sponsored Programs (OSP).
Voluntary Cost Sharing: When it is not a requirement of the sponsor and the university voluntarily proposes to cost share an expense, whether on the budget page or in the text of the proposal. Voluntary Cost Sharing also includes situations where a commitment is not made in a proposal, but the university absorbs costs which directly benefit the project, i.e., covering cost overrun. An agreement to cost share, whether voluntary or mandatory, represents a commitment subject to audit.
It is the policy of UAH to comply with applicable federal regulations and guidance regarding time and effort reporting. OMB Circular A-21 (relocated to 2 C.F.R. Part 220) outlines the guidelines governing effort reporting and the verification of salary distributions. Specifically, OMB Circular A-21 section (J)(10)(c)(2)(b) requires Effort Reports to be completed to provide after-the-fact verification of the salary charged to sponsored projects: “[Effort] Reports] will reflect an after-the-fact reporting of the percentage distribution of activity of employees.” Additionally, OMB Circular A-21 (relocated to 2 C.F.R. Part 220) requires that this verification be completed for all “professorial and professional” staff. At UAH, professorial staff includes all faculty members and professional staff includes all salaried staff and hourly employees involved in research activities. The Uniform Guidance also requires after-the fact verification.
To meet the requirements of OMB Circular A-21(relocated to 2 C.F.R. Part 220) and the Uniform Guidance, faculty members and salaried staff will certify effort reports three times a year as per the chart located in Appendix 2 to this Policy. OMB Circular A-21 states “[w]here the institution uses time cards or other forms of after-the-fact payroll documents as original documentation for payroll and payroll charges, such documents shall qualify as records for this purpose . . . .” The Uniform Guidance requires nonexempt employee salary and wages to be “supported by records indicating the total number of hours worked each day.” Thus, on-call hourly employees complete bi-weekly labor reports (BLR) and bi-weekly timesheets (WTE) to certify their effort.
Committing Effort
Each faculty and staff member must be aware of his/her level of committed effort to sponsored projects, their ability to meet those commitments in light of any other University obligations they may have and to communicate any significant changes in level of sponsored projects effort to OSP.
Faculty or staff are expected to commit at a minimum 1% of effort, (i.e., greater than 0%) on proposals in which they are listed as Principal Investigator (PI), Co-Investigator (Co-I), Project Director (PD), or key personnel. Since PI/PD or other key personnel have responsibility for the scientific, administrative, and financial management of an award, it is reasonable to expect that fulfilling these responsibilities requires time and effort. However, there are instances in which certain types of proposals do not require individuals to commit any level of effort. These exceptions include equipment and instrumentation grants, doctoral dissertations, student augmentation grants, and institutional or individual training grants for faculty mentors.
Expending Effort/Charging Salary
Salary charged to a sponsored project must never exceed the amount associated with the actual effort funded to that project.
UAH recognizes that salaries are sometimes mistakenly charged to the wrong project. The PI/Department Administrator should identify these situations when reviewing BLRs prior to approval. If an error does occur, the PI or Department Administrator must complete a cost transfer (aka: Labor Redistribution (Retro), if the error was made by the PI/Department Administrator. Cost transfers must have appropriate justification and documentation. If the error is due to data entry/processing caused by Payroll or Budgets and Management Information, then the PI/Department Administrator will notify the appropriate personnel (Budgets and Management Information/Effort Reporting Office) via email. This type of error will not require a Retro to correct if the Budgets and Management Information/Effort Reporting Office is notified within 28 days after the check date of the pay period affected. The Budgets and Management Information/Effort Reporting Office staff will prepare and process a Retro to correct this type of error. The Retro/Redistribution Policy is located at Exhibit C. All errors should be identified in a timely manner.
Summer Salary/Effort
Faculty compensated for 9-month academic appointments are permitted to expend up to an additional three months of summer effort on one or more sponsored projects in the period beyond the academic year (i.e., during the summer research period) and earn up to three months of additional salary for that effort, subject to sponsor policies.
However, if a faculty member has administrative or other non-research responsibilities during the summer period, they may be precluded from devoting 100% effort to sponsored projects and thus from requesting three months of salary from those sponsored projects.
The provisions of this Policy relating to the reporting and certification of effort apply fully to the reporting and certification of summer effort. Specifically, charging summer salary to one or more sponsored projects implies that at least a commensurate amount of effort has been expended on those projects during the summer effort period. Faculty who receive summer salary from sponsored projects must certify as to the effort expended on those projects during the summer effort period. Effort expended during the academic year cannot be counted for this purpose.
Certifying Effort
Financial penalties, expenditures disallowances, and harm to the University’s reputation could result from failure to provide accurate Effort Certifications or comply with the University’s effort reporting requirements. All individuals involved in the effort certification process are expected to abide strictly by the provisions of this Policy.
At the end of each certification period, the Budgets and Management Information/Effort Reporting Office will prepare Effort Reports for all individuals in departments and centers (w/ exception of on-call employees) that have charged or cost-shared salary/effort to a sponsored project. The Effort Report is provided to the recipient and may be made available to the recipient’s supervisor and other employees as indicated by the recipient on the effort report routing queue.
UAH effort distribution and certification reporting systems require that all effort identified with a sponsored program be classified consistently, regardless of whether the reporter’s salary is charged or cost shared to the sponsor.
If a change in effort as indicated on the Effort Report requires approval by the sponsor based on the terms and conditions of the agreement (e.g., many Federal awards require approval for a reduction in effort of more than 25% of the proposed amount, or as determined by funding agency, for key personnel), OSP will contact the PI/PD to discuss the change in effort before contacting the sponsor for approval.
The following rules govern the certification process:
- Effort Reports will be submitted to individuals electronically. Faculty members and salaried staff will certify three (3) times a year.
- Employees will review all effort reported on the Effort Report to ensure that it is correct and accurate to the best of their knowledge.
- If the Effort Report is correct, the individual will sign and date the certification via the Effort Certification Website not later than ten (10) business days after receipt.
- If the Effort Report is not correct, the individual has five (5) business days to submit a Retro with justification. See the Retro/Redistribution Policy (Exhibit C) for additional requirements and information.
- The approved Retro will be processed through the system within ten (10) business days after receipt in the Budgets and Management Information/Effort Reporting Office.
- The Budgets and Management Information/Effort Reporting Office will reissue the Effort Report within approximately 2 weeks of the Retro being submitted and processed.
- The employee has five (5) business days to certify the Effort Report via the Effort Certification Website.
- Timeline must be adhered to in order to ensure all certifications are completed and on file within ninety (90) days of the original certification release. If a responsible person does not communicate with the Budgets and Management Information/Effort Reporting Office regarding issues with the certification within the 90-day period, the Budgets and Management Information/Effort Reporting Office will remove the employee’s charges from all the awards within the certification period. (If an Effort Report is not certified, activities represented in the Effort Report constitute a False Claim, and must be removed.)
- Employees will be allowed to certify only once in a given reporting period. Re-certifications are allowed on an EXCEPTION only basis. (Effort Reports and corresponding labor records are locked when certified. No Retros are allowed on a locked certification without significant justification. See Exhibit D.)
Again, Effort Reports for persons who have charged effort to a sponsored project are certified via the Effort Certification Website within ten (10) business days. If there is consistent failure to complete Effort Report certifications, corrective action may be imposed at the discretion of the Vice President for Research and Economic Development and/or Vice President for Finance and Administration, and may include the freezing of sponsored program accounts until the Effort Reports are completed. Freezing of sponsored research accounts, to include applicable cost share accounts, will also prevent payroll charges to the sponsored or cost share accounts.
If changes are identified, the employee shall notify the Effort Compliance Officer. If sponsor contact is required, OSP will initiate additional actions that must occur to align the expenses charged to the project with the certified effort (e.g., cost transfer to adjust for any changes made to the Effort Report). In most cases, if the percent of salary charged is greater than the effort recorded, the difference will have to be removed from the contract/grant. For further information on Personnel Cost Transfers, please see the Retro/Redistribution Policy, Exhibit C. The Budgets and Management Information/Effort Reporting Office tracks the certification of Effort Reports and initiates any necessary follow up with the PI/PDs and department administrators to ensure 100% completion.
OMB Circular A-21 (relocated to 2 C.F.R. Part 220) requires that “reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed.” OMB’s Uniform Guidance states that “processes to review after-the-fact interim charges” must be included in the entity’s system of internal controls and be incorporated into the official records of the entity. At UAH, individuals certify their own Effort Reports. If an individual is unable to certify, the individual’s supervisor or other responsible official may certify that individual’s effort using a suitable means of verification. GRA certifications will be completed by the PI on the award or other responsible official. The electronic signature on the Effort Report is an endorsement by the employee that, to the best of their knowledge, the salary charges reasonably reflect the effort distribution across all activities. If the payroll distribution reflected on an Effort Report does not reasonably display how the employee spent his or her time, the employee must submit a Retro in accordance with UAH’s Retro/Redistribution Policy. Revisions to previously certified Effort Reports and payroll distributions may concern sponsors and auditors regarding the accuracy of the effort reports and effort certification process. Therefore, once the Effort Report is certified, changes are allowed on an EXCEPTION only basis. Exceptions are provided at the discretion of the Effort Compliance Officer and Vice President for Research and Economic Development, in accordance with UAH’s Retro/Redistribution Policy (see Exhibit C.)
Sanctions for Non-compliance
Failure to follow the provisions of this effort reporting policy may subject the individuals and departments responsible for the violation(s) to administrative and/or disciplinary actions in accordance with University disciplinary procedures and the judgment of management. Specifically, and without limitations:
- If Effort Reports are not completed and returned in a timely manner, salary costs associated with uncertified grant activity may be removed and charged to a department/center account or the researcher’s 4% account.
- The Vice President for Research and Economic Development may suspend submission of any new proposals on behalf of a noncompliant PI or inclusion of a noncompliant researcher in proposals, until Effort Reports are up to date and properly completed and certified.
- Submission of Effort Reports that are known at the time of submission to be materially inaccurate may expose the individual who completed the reports to personal disciplinary action.
Roles and Responsibilities
The Budgets and Management Information/Effort Reporting Office:
The Budgets and Management Information/Effort Reporting Office is responsible for preparing and distributing all Effort Reports.
The Budgets and Management Information/Effort Reporting Office is responsible for tracking the certification of the effort reports to ensure 100% completion. If Effort Reports are not returned within ten (10) business days, the Budgets and Management Information/Effort Reporting Office follows-up with the recipient. OSP may be contacted, depending on the follow-up needed.
Office of Sponsored Programs/Contract Administrator (CA):
The CA is responsible for notifying the sponsor of any changes in the effort commitments of individuals identified as key personnel and, where necessary, obtaining the sponsor’s approval of such changes.
Academic Departments
- Principal Investigator/Project Director (PI/PD): Each PI/PD is responsible for notifying OSP/CA of any changes in the effort of individuals listed as key personnel on respective sponsored projects, certifying that his/her efforts are reasonably reflected on the Effort Report, and ensuring that Effort Reports are certified within ten (10) business days.
- Staff Member with Effort: The salaried staff member on the sponsored project is responsible for certifying that his or her effort is reasonably reflected on the Effort Report.
