Section: SPONSORED PROGRAMS ADMINISTRATION
|Section 11000 Policies|
Policy Number: 11000.003.006
Policy Title: Effort Reporting
Policy Effective Date: December 1, 2011
Last Revision Date: December 1, 2011
(see revision history)
It is the policy of the California State University (CSU) that each campus shall develop and maintain policies and procedures for reporting all compensated effort of sponsored project related employees to ensure compliance with applicable regulations and agreements.
Each campus conducting research, instruction, and/or other sponsored work under grants, and other agreements funded by the Federal government are required to comply with 2 CFR 220 (formerly known as OMB Circular A-21) Section J.10, which describes the costing principles, criteria, and examples of how employee compensation for personal services rendered under sponsored agreements should be charged and subsequently documented.
At a minimum, the campus President or designee must ensure that:
- The campus has an effort reporting policy that defines roles and responsibilities of various offices and individuals at the campus. Upon establishing the policy, a number of offices might have the day-to-day responsibility for managing or contributing to the effort reporting process. Responsibility may rest with a number of the following offices including research and sponsored programs administration, academic affairs, the chief financial officer, the chief research officer, human resources, payroll, accounting, budget office, procurement, and extended learning.
- Regardless of where responsibilities lie, an effective effort reporting system requires coordination between two or more of the offices listed above. Effort reporting requires active engagement among a variety of campus offices such as sponsored programs administration staff, sponsored project personnel, and staff from the applicable academic and/or administrative office.
- Sponsored project personnel compensated on a federally sponsored award (direct cost or cost share) will certify a report that indicates that the distribution of their total effort is a reasonable estimate of work performed during the period covered by the report. The individual faculty or staff member may certify his/her own effort in accordance with procedures developed on the campus, or “responsible official(s) using suitable means of verification that the work was performed” may certify for the individual.
- Each campus will develop and maintain its own effort certification procedures for non-federal awards as appropriate.
- Each campus shall ensure that effort reporting is treated consistently for the same purposes and like circumstances.
- Effort certifications are completed each academic term, but not less frequently than twice annually.
Elements of Effort Reporting
Effort - Allowable activity devoted to a sponsored or non-sponsored project that would be charged or committed directly to a contract or grant. Effort shall be reflected as categories of activities expressed as a percentage distribution of total activities rather than the dollar amount compensated.
Compensated Effort - Effort consisting of campus assignment, reimbursed time, additional employment, direct pay, and cost share for faculty and staff who work on sponsored projects.
Voluntary Uncommitted Cost Sharing: Voluntary uncommitted cost sharing is excluded from effort reporting.
Executive Vice-Chancellor/Chief Financial Officer
Date: October 31, 2011
APPLICABILITY AND AREAS OF RESPONSIBILITY
RESOURCES AND REFERENCE MATERIALS
- The effort report should show the distribution of all compensated effort, including institutional base salary and additional employment, regardless of part-time or full-time employment status. For example:
- Faculty member is appointed 100% as AY instructional faculty and works 25% additional employment on a sponsored project – campuses should show the effort reflected as 100% for instruction and 25% additional employment. For campuses that prefer to show a conversion to a full-time equivalent, the effort reflected on the effort report would be 80% for instruction and 20% for additional employment, equaling 100%.
- A part-time faculty member who is appointed 25% as a lecturer and 25% on a sponsored project – the effort reflected on the effort report would be 50% for instruction and 50% additional employment, equaling 100%.
OMB Clarification Memo M-01-06 from January 5, 2001. “Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Memo” http://www.whitehouse.gov/omb/memoranda/m01-06.html
Certification - A signed statement by the employee or responsible official on the sponsored project that attests to the accuracy and completeness of the report.
Cost Sharing - The portion of the project/program costs that are contributed by the recipient. Cost sharing can be required by the sponsor (mandatory), or voluntary on the part of the recipient.
Direct Costs - Costs associated with activities from which the project derives a direct benefit and can be readily and specifically attributed to the project or program.
Salary Cap - A limitation imposed by the sponsor on the amount of salary that can be directly charged to projects.
Voluntary Uncommitted Cost Sharing - Effort that is over and above that which is committed and budgeted for in a sponsored agreement. Voluntary uncommitted effort is not required to be documented or tracked.
- Board of Trustees Executive Order No. 890 Section 3.3.3
- COGR Management Practices Document – http://www.cogr.edu
- 2001 letter from DHHS indicating CSU Additional Employment Policy is compliant with A-21
- NSF/CSU/SDSURF resolution regarding additional employment on NSF grants
Sound Business Practices:
- CSU Bakersfield - http://www.csub.edu/grasp/ (Program Administration Guide)
- Fresno State - http://www.csufresno.edu/aps/documents/apm/504.pdf
- CSU Long Beach - http://www.foundation.csulb.edu/departments/grants/pimanual/Section4pdf.pdf
- CSU Monterey Bay- http://grants.csumb.edu/site/x3315.xml
- San Francisco State - http://www.sfsu.edu/~orspwww/_policies/_docs/TimeandEffortReportingPolicy.pdf
- San Diego State - http://www.foundation.sdsu.edu/pag/project_admin_other_compliance_issues.html#3
Laws, State Codes, Regulations and Mandates:
- CSU Additional Employment Policy HR2002-05–http://www.calstate.edu/HRAdm/pdf2002/HR2002-05.pdf
- CSU Collective Bargaining Agreement, Unit 3 – Article 20 and Article 36 -http://www.calstate.edu/LaborRel/Contracts_HTML/CFA_CONTRACT/CFAtoc.shtml
- Code of Federal Regulation 2 CFR PART 220 (formerly known as OMB Circular A-21), Section J.10. http://www.whitehouse.gov/omb/circulars_a021_2004/
COGNIZANT OFFICE(S)CO Manager:
Ms. Sue DeRosa
Director, Sponsored Programs
CSU Office of the Chancellor
Ms. Monica Kauppinen
Ms. Renee Lechner
Ms. Laramee Lyda-Craft
Ms. Alison Sanders
RAC, CCRO, FOA, CABO, HR