Certification of Effort
Find instructions on accessing and certifying electronic Effort reports through My4D.
The purpose of our Standard Operating Procedures are to document effort in direct support of sponsored programs. Details can be found here.
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Definitions
1. Effort is the percentage of time that is expended to fulfill an employee’s obligations to the University. The total Effort across all duties and obligations must equal one hundred percent (100%), regardless of how many hours are worked.
2. Uniform Guidance established by the Office of Management and Budget at 2 CFR § 200 is the uniform administrative requirements, cost principles, and audit requirements for determining costs applicable to grants, or agreements between educational institutions, such as the University and any agency of the federal government.
3. Principal Investigator is a University employee that leads a given program or project and is responsible for the proper conduct of research or other activity described in the proposal, grant, or instrument of agreement for the specific program or project. 2
4. Responsible Person is a University employee who has sufficient and verifiable knowledge of the work being performed on a given Sponsored Program, including regular duties and responsibilities.
5. Sponsored Programs are programs or projects that are funded by an external entity through a written agreement (grant, agreement, or other instrument) with the University. Sponsored Programs include specific research, training, or service programs and projects.
6. Suitable Means of Verification are the written documents that are sufficient to confirm or support the Effort expended by an employee on a Sponsored Program. Examples include, but are not limited to, teaching schedules, leave reports, calendars and correspondence, award work products, and grant timesheets. An oral verification is not a Suitable Means of Verification
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Policy
The University receives federal funding and is, therefore, subject to the requirements established by the OMB contained within Uniform Guidance (2 CFR 200). The Uniform Guidance requires that institutions maintain a system of internal controls that provide reasonable assurance that charges to a Sponsored Program are accurate, allowable, and properly allocated. The Uniform Guidance (2 CFR § 200.430) requires that each grant recipient document time expended towards the Sponsored Program. Recognizing the unique nature of universities, the Uniform Guidance (2 CFR § 200.430) requires documentation and certification of the percent ofEffort expended toward Sponsored Programs. To meet the requirements for documentation and certification, employees paid monthly, who provide any type of service toward a Sponsored Program, shall certify their Effort based on distribution of total hours worked during that month. All employees are responsible for certifying their own Effort. Uniform Guidance (2 CFR § 200.430) requires an employee’s Effort be certified by a Responsible Person with reference to Suitable Means of Verification that the work was performed, and the employee’s certified Effort is appropriate. The full policy can be found here.
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Roles & Responsibilities
Employee is responsible for submitting payroll documents that reflect the actual distribution of effort as accurately as possible, reviewing the effort distribution report, and certifying to its accuracy. Follow these instructions on How to Run Data Insights Report.
For more information surrounding the specific roles and responsibilities, please follow this link.
Certification of Effort FAQs
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Why do I Have to Certify Effort?
The OMB Uniform Guidance (2 CFR 200) requires that personnel associated with sponsored activity certify their effort after the effort has been expended. A certified effort report is the only auditable document the university has to support salary costs on an award. Failure to have a certified effort report on file for payroll costs on an award could result in the disallowance of the related salary, fringe and F&A costs.
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When is Effort Certification Required?
Uniform Guidance 2 CFR § 200.430 requires that each grant recipient document time expended towards a sponsored program. Recognizing the unique nature of universities, Uniform Guidance 2 CFR § 200.430 requires documentation and certification of percent of effort, totaling 100%, in support of one’s total commitment toward sponsored programs. To meet this requirement for documentation and certification, individuals paid monthly and who has some commitment towards a sponsored program, shall certify their effort based on the distribution of total compensation paid to the individual during that month.
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How Often do I Certify my Effort?
Reports for Faculty are to be generated on a quarterly basis (January – March, April – June, July – September, and October – December) and reports for other Employees and Staff are generated monthly by the Office of Research and Sponsored Programs utilizing the University financial management system (Banner). A reminder email is automatically generated by Banner and sent to Employees whose Effort certification is not completed within 30 days of the report being generated.
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What Happens if I Don’t Certify My Effort?
DU has administrative consequences for failing to certify effort.
Consequences for individuals who do not fulfill their responsibilities include the removal of services associated with:
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Submitting grant proposals or other project applications to sponsors for extramural projects.
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Negotiating and executing award agreements.
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Establishing accounts for spending external funds for new or continuing projects.
In addition to the consequences outlined above, DU has fiscal consequences for uncertified effort. If effort reports are not certified before the conclusion of fiscal year end (June 30), the payroll expense may be determined to be unallowable and will not be reimbursed by the Sponsored Program fund causing the applicable payroll expense to be borne by the employee’s department. All incidences where Effort is not timely certified will be reported to the Vice Provost for Research.
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Who Can Certify an Effort Report?
Employees certify their own effort report.
- Principal Investigators must:
- Certify their own effort quarterly
- Coordinate with their grant staff to ensure they are certifying their effort
- Staff Members (post-docs, graduate research assistants, etc) must:
- Certify their own effort monthly
- Department Administrators must:
- Be responsible for onboarding and employee departure processes
- Review the document “Open Effort Certification Report” (could we link to this?) to help identify open effort certifications
- Provide reminders to PIs
- Sponsored Programs Administration Staff must:
- Work with department administrators to gather necessary information to approve effort for employees who have left the University
- Keep effort certification records up to date by working with PIs, staff, and DAs.
If an employee is no longer employed at the university, the sponsored programs team will work with the appropriate person in the department to certify.
See attachment for “How to Run Data Insights Report” for data insights instructions.
- Principal Investigators must:
- How is it Certified?
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What if the Report is Incorrect?
If changes to an Effort Report are needed, do not certify the report. Communicate the correct effort percentages for the period to your Department Administrator or Budget Officer. The appropriate person in your department will prepare a Payroll Redistribution Request. Once the payroll changes are posted, a revised Effort Report will be generated.
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What Does a Department Administrator do to Check Open Effort Certification?
As a Department Administrator you are responsible for:
- Onboarding new faculty and introducing the effort certification process, as well as ensuring departing employees certify their effort before they depart.
- Help identifying open effort certifications by running the Effort Certification Report on a regular basis. See “How to Run Data Insights Report” for instructions on how to run this report.
- Providing reminders to PIs and students/grant employees.