PURPOSE OF THIS POLICY
As a leading research institution, Colorado State University recognizes the importance of providing good stewardship in managing extramural funds. The University’s stewardship responsibilities include complying with federal requirements to verify faculty and staff effort on sponsored projects.
Support for the faculty's research goals is critical to the success of the University. The purpose of this policy is to foster excellence in research by promoting the successful management of effort and commitments throughout the sponsored project life cycle; comply with provisions of the federal Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), 2 CFR Part 200, regarding effort certification and other relevant sponsor requirements; provide clear direction to faculty and staff for determining effort when preparing proposals and subsequently verifying effort; promote the best possible alignment between faculty and staff activity and funding sources; and establish expectations for tracking and confirming the certification of effort by University personnel.
APPLICATION OF THIS POLICY
This policy applies to all University business units, faculty and other employees engaged in research funded by extramural sponsors (53-fund accounts).
DEFINITIONS USED IN THIS POLICY
Academic Year – For effort reporting purposes, an academic year is the period of a faculty member’s appointment. CSU faculty are generally appointed for either 9 or 12 months. 9-month appointments can relate to either a specific 9-month period or 9 months’ work spread over the fiscal year, and 12-month appointments include all months during a fiscal year.
Certification – The assertion by a PI/faculty or designee that the salaries charged to sponsored projects as direct charges or cost sharing reasonably reflect the effort expended, work performed, and any allowable paid absences permitted under University policy or emergency guidance during the reporting period. These certifications are a required process to accept sponsored funding.
Certification Period – After each fiscal quarter has ended, a Certification Period begins. There are two parts to each Certification Period. Once the period opens, effort coordinators have 30 days to review each project and process any salary transfers (Past Period Distribution Adjustments, or PPDAs) before the PI is notified that the Project Certification is open for them. Effort Coordinators are expected to communicate with the PIs about any questions. There is then another 30-day time interval for PIs or designees to certify the effort and salaries charged to their projects during the reporting period. Changes may still be made at this time, but if the Effort Coordinator has already met with the PI to go over the accounts, changes during the PI Project Certification Period will already have been addressed.
Committed Effort – Amount or percentage of time an individual has communicated to the sponsor that he or she will work on a specific sponsored project over a specified period of time. Commitments are made in the proposal and may be documented by the sponsor in award documents. Changes to reduce committed effort may require sponsor approval. Changes to increase committed effort do not need sponsor approval unless re-budgeting authority is necessary.
Cost Sharing – Any project costs that are not borne by the sponsor. Cost sharing of effort is the provision of faculty and/or staff time and related fringe benefits that were committed and provided in support of a project but are paid by other sources of funding, and becomes part of the effort commitment that is certified. Cost-shared effort in excess of the commitment made in the proposal is non-reportable to the sponsor.
Designee – Authorized delegate of certification responsibilities on a specific sponsored project (other than the PI) for the Quarterly Project Effort Certifications. A fillable form for requesting delegation of authority is available from Sponsored Programs using this link.
ECC – The Employee Compensation Compliance system is the electronic effort reporting system used by Colorado State University. Information on the system may be found online from Sponsored Programs.
Effort Reporting - 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 and any allowable paid absences permitted under University policy or emergency guidance during the reporting period. Effort statements are also referred to as “certifications” or “reports.”
Fiscal Year - CSU’s Fiscal Year is from July 1 – June 30. CSU’s project certification cycle runs on the CSU Fiscal Year calendar.
Institutional Base Salary (IBS) – Compensation guaranteed by the University for an employee’s appointment (9 or 12 months), whether that individual’s time is spent on research, teaching, or other activities. IBS does not include bonuses, one-time payments, or incentive pay. Additionally, IBS does not include supplemental payments from other organizations or income that individuals are permitted to earn outside of their University responsibilities, such as consulting. IBS must be used as the base salary on all grant proposals unless there is a statutory limit on compensation (e.g. NIH cap). See the CSU Policy on Institutional Base Salary.
Key Personnel – The program director/principal investigator and other individuals who are responsible for the scientific design, conduct, and execution of a project in a substantive, measurable way, whether or not they request salaries or compensation.
Period of Work Performed – This is another way of referring to the quarterly reporting period and represents the fiscal quarter during which an employee performs effort. The period of work performed for quarterly project certifications are fiscal quarters, July-September (Q1), October-December (Q2), January-March (Q3), and April-June (Q4). The period of work performed may also be referred to as the reporting period.
PI/Faculty Effort – The proportion of time spent by an academic appointee on any University activity expressed as a percentage of time. 100% effort is the total time spent on University work within the scope of their academic appointment period (9 or 12 months), regardless of how many or how few hours an individual worked in the reporting period. The total effort reported for a PI/faculty member will always equal 100%, even if he or she is less than 1.0 FTE. Total academic period effort includes sponsored projects and non-sponsored activities that are funded by the University including work performed outside of normal work hours and work performed off-campus. See Institutional Base Salary (IBS) for more information.
Project - For effort reporting purposes, “project” is the unique combination of a fund, activity and sub-activity as set up in the financial system (KFS) and charged in the general ledger. Sponsored projects always start with the designation “53,” although cost-sharing accounts will generally have another designation (“16” or “14” for instance).
Salary Cap – A maximum annual rate of CSU salary for full-time effort that can be charged to an agency's award. NIH salary caps are indexed to a specific Government Executive Pay Level, e. g. Executive Level 2. The salary for the Executive Pay Level may vary for each Government Fiscal Year in which the funds are awarded (usually on January 1). The ramification to effort reporting is the need to set up a companion cost sharing account to cover salary expenditures over the cap.
Summer Salary - Faculty compensated for 9-month academic appointments are permitted to earn up to an additional three months of summer paid compensation on one or more sponsored and/or non-sponsored activities. Individuals can earn up to the equivalent of three months of additional salary for that effort, subject to college and sponsor policies and the appropriate college level approval. If a faculty member has administrative or other non-sponsor related responsibilities (including vacation or proposal preparation/writing) during the period for which they are requesting summer salary, they are precluded from devoting the maximum allowable 100% effort to sponsored projects and cannot request the full 100% of 3 months of salary from sponsored projects. Summer salary is not included in IBS.
Supplemental Pay - Compensation by the University beyond the established base salary of a faculty member or administrative professional. Supplemental pay is intended for University activity that requires effort, either in degree or nature, in addition to that defined under the individual’s appointment and their one hundred (100) percent effort distribution. Supplemental pay is not included in IBS.
Voluntary Uncommitted Cost Sharing (VUCS) – University faculty or senior researcher effort that is over and above that which is committed and budgeted for in a sponsored agreement. This differs from mandatory or voluntary committed cost sharing which is cost sharing specifically pledged in the proposal’s budget or award. Effort relating to VUCS does not need to be charged to federal awards or certified.
The policy of Colorado State University is that all researchers who engage in sponsored projects will comply with federal agency requirements and University policies on effort reporting, cost sharing, cost transfers, institutional base salary, the allocation of direct and indirect costs and sponsoring agency regulations regarding the proposing, charging, and reporting of effort on those projects.
Activities during which effort issues are important include:
- Establishing faculty and staff appointments and professional duties
- Proposing effort in an application for a sponsored project
- Establishing effort commitments at the time an award is made
- Charging salary, documenting cost sharing, and expending effort during the life of a project
- Monitoring progress toward the fulfillment of effort commitments to specific projects
- Managing an individual's total commitments across all projects
- Certifying that salary charges are reasonable in relation to the work performed (and any allowable paid absences permitted under University policy or emergency guidance), and that commitments to sponsors have been met, using the ECC system.
- Actual effort expended on each project must be certified at the end of specified reporting periods by a responsible person with suitable means of verification that the work was performed and the salary charges are appropriate (generally the principal investigator). The effort certification should be a reasonable estimate of how time was expended.
- Generally, faculty cannot commit 100% of their effort on sponsored projects, as time must be reserved for other CSU duties. For Administrative Professionals and State Classified staff, up to 100% of effort may be devoted to sponsored projects. However, allocations of effort to sponsored projects must be reasonable given the individual’s non-sponsored University activities.
- Effort must be certified for all individuals who receive salary support from a sponsored project and those who expend committed effort on a sponsored project without receiving salary support from the sponsor. Principal Investigators certify the effort of all staff on each project. Project effort reports must be certified in a timely manner in the ECC system.
- The effort devoted to a sponsored project should be consistent with the plan that was proposed to the sponsoring agency and agreed to at the time of the award. All Key Personnel must devote at least a one percent commitment to that project, with a few exceptions such as equipment grants, and dissertation grants. All principal investigators, faculty, and staff who are involved in proposing, executing, directing, or managing sponsored projects are responsible for:
- understanding the fundamentals of effort and commitment management and effort certification
- proposing, expending, and managing effort in accordance with the award and all applicable sponsor policies and University procedures
- completing any required educational programs associated with effort reporting
COMPLIANCE WITH THIS POLICY
CSU employees who expend effort on sponsored projects are required to comply with this policy. Failure to do so can result in project costs being disallowed, as well as fines and penalties imposed by the funding agencies. For assistance with compliance, please review the CSU Guidelines referenced below or contact the Office of Sponsored Programs:
Address: 601 South Howes Street, 408 University Services Center
U.S. Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance for Federal Awards), 2 CFR Part 200
CSU Policy on Cost Sharing for Sponsored Projects
CSU Policy on Institutional Base Salary
PROCEDURES, FORMS AND TOOLS
CSU Guidelines for Project-based Effort Reporting: Proposing, Managing, and Certifying Effort Associated with Sponsored Projects, contact Sponsored Programs.
Approved by Anthony A. Frank, President, February 13, 2018
Revision approved by Lynn Johnson, Vice President for University Operations on August 15, 2018
Revision approved by Lynn Johnson, Vice President for University Operations, on August 10, 2020
Revision approved by Lynn Johnson, Vice President for University Operations, on December 31, 2020