[Occasionally, we like to revisit posts from days gone by that either (1) are always relevant, or (2) are the subject of recent questions received by our office. Today’s Oldie But Goodie falls into both categories, as effort reporting continues to be the subject of many discussions involving ORA.]
Originally Published October 3, 2011
Of the myriad questions we receive each day from analysts and PIs alike, none can be more tricky to address than those regarding effort reporting. Naturally, keeping accurate records regarding effort is an important part of the research process, not just because of the financial ramifications to the PI, but also because of the potential audit landmines that arise when effort numbers don’t add up.
To help shed light on this complicated topic, the National Council of University Research Administrators (NCURA) recent published a Top Ten list of the things that every PI should know about effort reporting:
1. Effort is your work on a project, whether the sponsor pays your salary or not.
2. When you write yourself into a grant proposal, you are committing your effort to the sponsor.
3. If you reduce your effort, paid or unpaid, on a federal grant by 25%, you must have agency approval. If you reduce your paid effort, you may choose to document cost-sharing so that the total effort does not decrease.
4. Many activities cannot be charged to a federally sponsored project. For example, the time you spend on these activities cannot be charged:
- Writing a proposal
- Serving on an IRB, IACUC or other research committee
- Serving on a departmental or university service committee
5. If you work on a sponsored project, you must certify your effort.
6. Certifying effort is not the same as certifying payroll.
7. Certification must reasonably reflect all the effort for all the activities that are covered by your University compensation.
8. Effort is not based on a 40-hour work week. It’s not based on hours at all.
9. Effort must be certified by someone with suitable means of verifying that the work was performed.
10. In identifying audit findings, auditors look for indications that certification was based on factors other than actual, justifiable effort.
One important thing to keep in mind is that, in #3, the 25% figure is a percentage of the original amount, not a numerical percentage decrease of 25. For example, if your original effort on an NIH grant was listed at 50%, but you decide to reduce it to 35%, the actual reduction of effort is 30%, and thus you will need agency approval.
While the above are useful in helping to understand a complicated process, we’re sure that there are other considerations not listed. So, what are some additional recommendations/pieces of advice that you give to PIs and departments to ensure that everything runs smoothly?