Responsible Administrative Unit:

Time and Effort
Office of Research Administration
Reporting Policy

Policy Contact:

Director, Office of Research
Issued: December 2013
Administration


Revised:
rabrown@mines.edu




1.0
BACKGROUND AND PURPOSE

This establishes the school’s policy and procedures for obtaining effort
certifications for employees whose salaries are paid pursuant to sponsored
agreements.

Personnel costs typical y represent the single largest expense charged to
federal y sponsored awards. Accordingly, the government requires that
institutions receiving federal funds for sponsored agreements maintain an effort
certification process that complies with the requirements set forth in 2 CFR Part
220 (OMB Circular A-21).1
.

2.0
POLICY

Federal regulations set forth criteria for acceptable methods of charging salaries
and wages to federal y sponsored projects. These regulations also require that
institutions develop a mechanism to determine how individuals actually expend
effort and prescribe criteria for acceptable methods of documentation.

Federal regulations require a periodic certification, by employees or persons
having direct knowledge of the employee’s activity, to confirm reported effort. The
effort reporting system used by the School is an “after the fact” activity report that
records effort based on payrol charges to the sponsored project. Faculty and
exempt employees are asked to complete a Time and Effort Report (certification)
three times per year since work can fluctuate from pay period to pay period. All
other employees are required to submit bi-weekly or monthly time sheets.

The certification must accurately reflect the time Principal Investigator (PI) spent
not only on performing the research but also on other related tasks such as
preparing proposals and conducting other administrative work. Therefore 100%
of effort cannot be certified on sponsored awards.

PI effort is not required on sponsored projects for equipment and instrumentation,
doctoral dissertations and student augmentation and limited purpose grants such
as travel grants.

1 2 CFR Part 215 (OMB Circular A-110) Uniform Administrative Requirements for Grants and
Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
Page 1 of 4




Responsible Administrative Unit:

Time and Effort
Office of Research Administration
Reporting Policy

Policy Contact:

Director, Office of Research
Issued: December 2013
Administration


Revised:
rabrown@mines.edu




Prior agency approval is required to reduce PI or key personnel effort by 25%, or
if the PI or key personnel are absent for more than three months.


3.0
PROCEDURES

The school uses a three times per year certification period to accomplish its effort
certification requirement. Al Academic Departments conducting research wil
receive Time & Effort Reports for distribution to employees assigned to their
departments based on the schedule below:


♦ Research performed Jan, Feb, Mar, Apr – reports distributed by June 1
♦ Research performed May, Jun, July, Aug – reports distributed by Oct 1
♦ Research performed Sept, Oct, Nov, Dec – reports distributed by Feb 1

Federal regulations acknowledge the process of costs and effort cannot always
be exact. These regulations provide the fol owing acknowledgement: "In the use
of any methods for apportioning salaries, 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." Colorado School of Mines seeks to
certify effort within +/-5%.

Upon review of the labor distribution, redistribution may be necessary to transfer
labor charges from one index (fund/org/acct/program code) to another. Because
a precise appraisal of factors contributing to costs/efforts is not always feasible or
expected, if errors above + or - 5% are recognized, a payrol redistribution should
be initiated. The payrol distribution request form is located at (click link to go to
Payrol or copy and paste link to go directly to the form):
http://inside.mines.edu/UserFiles/File/finance/controller/CSM_Docs/PAYROLL REDISTRIBUTION REQUEST FORM.xls

Recertification:

Once payrol has been certified to a particular index, ORA wil approve a payrol
redistribution that moves that payrol to another index only as an exception.
Such transfers require documentation that adequately justify a change in the
previous certification and must comply with the ORA Cost Transfer Policy. If a
payrol transfer moves salary that is greater than 180 days old the PI must
Page 2 of 4




Responsible Administrative Unit:

Time and Effort
Office of Research Administration
Reporting Policy

Policy Contact:

Director, Office of Research
Issued: December 2013
Administration


Revised:
rabrown@mines.edu



provide a written statement to ORA that explains how this benefits the project
receiving the expense, why this project did not receive the charges when they
first occurred and why it took so long to initiate a transfer. Once an effort report
has been certified any changes to that effort report resulting from a payrol
redistribution request wil require the entire effort report to be recertified.


RESPONSIBILITIES:

Principal Investigators, faculty and staff are responsible for timely certification of
their Time and Effort reports three times a year. In the event the PI, faculty or
staff is unable to certify the effort report, a surrogate having firsthand knowledge
or a suitable means of verification of the work performed may certify the report
(e.g., the Department Head, Division Director, or a Co- PI).

When certifying time and effort for a set period of time, ensure that the actual
dates worked are within the time period of certification and do not fal outside of
the time period that is being certified.
DEFINITIONS:

Effort - Work or the proportion of time spent on al compensated school activities,
including restricted and matching fund sources and expressed as a percentage
of total time. Total effort for an employee must equal 100%, serving as the basis
for an individual's effort.

Firsthand knowledge – Direct evidence of work performed. One may have this
knowledge of work performance by either performing the work or through
supervising the individual performing the work.

Labor Redistribution - An adjusting or correcting internal accounting transaction
to transfer salary and fringe benefit charges from past pay periods from one
index (fund/org/acct/program code) to another.

Principal Investigator - Principal Investigator (PI) is the head of a research
project. General y, CSM policy requires that a research proposal may be
submitted only by permanent, ful -time faculty at CSM who wil personal y
participate in the project in a significant manner and also serve as the Principal
Investigator. Part-time, retired, visiting, etc., faculty may participate on research
projects as Co-Principal Investigators. If an exception is needed for someone
who is not permanent, ful -time faculty, the approval must come from the
Page 3 of 4




Responsible Administrative Unit:

Time and Effort
Office of Research Administration
Reporting Policy

Policy Contact:

Director, Office of Research
Issued: December 2013
Administration


Revised:
rabrown@mines.edu



appropriate department head and the V.P. for Research. By exception, the
School may approve the submission of a contract and grant proposal by other
part-time, retired, visiting faculty participating on research projects as Co-
Principal Investigators. If an exception is needed for someone who is not
permanent, full-time faculty, the approval must come from the appropriate
department head and the V.P. for Research.

Sponsored Projects - An external y-funded activity that is governed by specific
terms and conditions. Sponsored projects must be separately budgeted and
accounted for, subject to terms of the sponsoring organization. Sponsored
projects may include grants, contracts, and cooperative agreements for research,
training, and other public service activities.

Suitable means of verification – The process through which one receives
assurance that work was performed so as to provide a certification of effort on an
effort report. This process must take into consideration other school records and
provide for the documented review of such records in support of work performed.
Examples of these records may include the fol owing: calendars, teaching
schedules, logbooks, or sponsor budgets. Other means of verification may also
suffice, including e-mails attesting to effort devoted based upon firsthand
knowledge. Oral verification from the PI, faculty or staff to an administrator wil
not suffice as a suitable means of verification.


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