1315 PR.04 Effort Reporting

Revision Date: 
February 26, 2016

Information And Processes 1

Timing. 1

Effort Report Template. 2

Effort Reporting Requirements For An Exiting PI/Faculty Member 2

Effort Reporting Requirements for PI/Faculty Member Who Have Left Yale. 3

Roles and Responsibilities 3

Access to the Effort Reporting System.. 4

Completing The Certification Process 5

Task Summary Matrix. 6

Monitoring And Departmental Escalation During The Certification Cycle. 7

Notifications During The Certification Cycle. 8

Frequently Asked Questions 8

Appendix. 12

Prior to 12/26/14 2 CFR Part 220 (OMB Circular A-21) applies to all federal awards.  All new awards and new money awarded on or after 12/26/14 is subject to 2 CFR Part 200 (OMB Circular A-81, commonly referred to as Uniform Guidance) unless otherwise stated.  This procedure is compliant with 2 CFR Part 200 standards for documentation of personnel expenses.

Information And Processes

What is effort reporting?

Effort reporting is the process the University utilizes to document effort expended on sponsored projects during each effort reporting period. The effort report form is the mechanism through which effort devoted to sponsored projects, teaching, clinical practice, and other activities, expressed as a percentage of total University effort is documented.

Note:  Certification for certain personnel that are paid weekly, such as undergraduate students, service and maintenance staff is accomplished through signature verification by the appropriate individual within the certification block on the Temporary Employee Payment Request form 3501 FR.05. For departments using the eTimesheet system for students, the supervisor of the student certifies electronically to the hours worked. 

The following individuals in the situations described below do not need to complete an effort report nor will they receive an effort report:

  • Graduate Students supported 100% by a training grant.
  • Yale Personnel who are 100% devoted to an Interpersonnel Agency Agreement (IPA) with a federal agency.

 

Timing

The effort reporting periods for covered individuals and required frequency are illustrated in the Table below.  It should be noted that shortly after the close of an effort reporting period, effort reports are initiated by the  Office of Sponsored Project’s Central Administrator.

Effort Period

Covered Individuals

Spring and Fall Academic Term (January & June)

Graduate students

Summer (September)

Graduate students and 9-month Faculty summer compensation

Semiannual (January & July)

Professionals, Faculty and Staff

Note:  It is the responsibility of the CA to monitor effort reporting activities utilizing Yale’s Effort Reporting System’s (ERS) reporting tools.  Such monitoring includes the rate of completion by departments.  Effort reports are expected to be certified within 60 calendar days from the date of availability notification. ERS also provides the CA with an email notification tool to alert Department and Sub Department Coordinators, and Pre Reviewers of effort report availability once a reporting period has been initiated. 

Effort Report Template

If an individual devoted some percent of committed effort to a Yale sponsored project and ERS did not generate an Effort Report (ER), an Effort Report Form template must be completed and certified.

The following are examples of when an effort report is not automatically generated in ERS and the use of an effort report template would be necessary:

  •     Covered individual is on the Executive (Confidential) Payroll
  • Covered individual is on a sabbatical leave for the entire effort period and is continuing his/her commitment to the sponsored project
  • Individuals paid 100% by a non-Yale source and devoting effort to Yale sponsored awards (i.e., Howard Hughes Medical Institute or the Veterans Affairs Connecticut Healthcare System).

If a situation occurs where an effort report is not generated, it is the responsibility of the operations manager or lead administrator to complete the effort report template, ensure that it is appropriately certified, and submit the effort report according to the instructions on the template.

Effort Reporting Requirements For An Exiting PI/Faculty Member

Prior to a Principal Investigator’s (PI) or faculty member’s permanent departure from Yale, s/he is required to complete the requisite effort reports for him/herself and those for which they are directly responsible.

If the PI is transferring awards to another institution, effort reports should be submitted prior to Yale’s relinquishment or transfer of the award.

The steps below provide guidance on how to complete an effort report when the certifier is leaving Yale during an effort reporting period (i.e., the Effort Reporting System has not yet generated a report for the applicable period).  The completion of this effort report  does not replace certification in the system of record (ERS) but rather serves as supporting documentation for the certification of the ERS generated effort report form.  

  1. Review the PI’s portfolio of awards.  Identify effort commitments and associated sponsored project accounts (including cost sharing).
  2. Identify all individuals charged to the awards.
  3. Confirm the distribution of salary of all individuals charged to the account(s) indicated in the labor schedule or aid line(s) via financial statement review (i.e., the Account Holder Report, Bug 101a, Bug 101b, Payroll Earnings Detail Report, Review Tool, etc.).  Adjust any labor that may have gone to suspense or to an incorrect account in the appropriate source system (LD or GSPS). 
  4. Use the Effort Report Form template to create an effort report for each individual identified. 
  5. Obtain a signature from the appropriate individual (covered individual, PI or designee) in accordance with the Effort Reporting Policy
  6. If the actual effort indicated by the certifier differs from the payroll percentage identified, discuss the difference with the certifier and correct the labor accordingly (LD or GSPS).
  7. Retain the effort report(s) and any supporting documentation on file in the department. 
  8. When effort reports are initiated in ERS according to the defined frequency, complete the Pre Review process.  The previously completed effort report template should correspond to the ERS generated effort report.
  9. If the payroll percentages do not match the actual effort indicated by the PI (or designee) on the effort report template, correct accordingly.   
  10. Assign the DC or SubDC of the department as certifier in order to complete the certification process. This is permissible due to the existence of an effort report in paper form that supports the ERS certification.
  11. Print the ERS certified effort statement(s) and attach all supporting documentation, including the signed effort report template(s), and retain all documents on file in the department.  The completed effort report must also be forwarded to the Effort Reporting Central Administrator at effort.reports@yale.edu.

 

Effort Reporting Requirements for PI/Faculty Member Who Have Left Yale

Employees with a terminated assignment in HR no longer have access to the Effort Reporting System.  Contact the OSP Effort Reporting Central Administrator (CA) via email at effort.reports@yale.edu for the proper procedure to follow if certification was not captured prior to the individual’s departure from the University. 

Roles and Responsibilities

Central Administrator (CA)

The Effort Reporting Central Administrator (CA) determines which reporting periods need to be initiated and when initiation will occur.  The CA generates effort reports for all departments and notifies Department Coordinators, Sub Department Coordinators and Pre Reviewers via e-mail when effort reports are ready for the certification process.  The CA monitors overall completion by department for the University, performs routine system maintenance to ensure data integrity, and supports the certification process. 

Division Head (DH)

The Division Head (DH) role is typically held by a member of the Business Operations Leadership Team (BOLT) or his/her designee.  The primary role of the DH is to:

  • assist departments with the resolution of known issues  preventing the certification of effort; and
  • assist Department Coordinators in ensuring the timely resolution of uncertified effort reports.

 

Department Coordinator (DC)

The Departmental Coordinator (DC) plays a critical role in the certification process.   DCs are responsible for:

  • determining and assigning responsibility for pre and post review activities;
  • ensuring that Pre- and Post-Reviewers have received required training;  
  • understanding effort reporting requirements for federal agencies and non-federal sponsors and associated Yale policies and procedures;
  • disseminating effort reporting policies and procedures to investigators and research administrators in their departments;
  • understanding the department’s sponsored awards which includes but is not limited to proposal budgets, effort commitments, and the terms and conditions of the awards as well as sponsor guidelines/policies;
  • providing assistance to staff and faculty who participate in the effort process and use of Yale University’s Effort Reporting System (ERS);
  • guiding certifiers in the use of the ERS;
  • responding to questions initiated by department personnel regarding effort reporting policies and procedures;
  • determining if cost sharing is captured properly;
  • determining if cost transfers are made in accordance with University policies and sponsor terms and conditions;
  • monitoring the timely completion of effort reports;
  • escalating to the DH for their assistance, issues that may impede the timely completion of effort reports; and
  • performing Pre and Post Review duties in the ERS when appropriate.

 

Sub Department Coordinator (SubDC)

The Sub Department Coordinator has the same responsibilities, competencies and training requirements as the Department Coordinator but at the sub department (Yale University organization) level.

Pre and Post Reviewer

Pre and Post Reviewers are an integral part of the effort reporting process.  The Pre and Post Reviewer:

  • assists the DC or SubDC in facilitating a timely and efficient process for those individuals required to certify effort;
  • reviews effort reports and makes appropriate adjustments both prior to and after review by the certifier;
  • understands the sponsored accounts included on the effort reports assigned to them for review, including but not limited to proposal budgets, effort commitments, the terms and conditions of the sponsored award as well as sponsor guidelines/policies;
  • provides assistance to faculty who participate in the effort process and use of ERS;
  • captures cost sharing properly;
  • completes cost transfers in accordance with University policies and sponsor requirements; and
  • ensures that effort reports are reviewed and properly escalated for timely certification in accordance with the due dates established by the University.

 

Certifier

Each faculty member must be aware of his/her level of committed effort to sponsored projects, the ability to meet those commitments in light of any other University obligations s/he may have and to communicate any significant changes in the level of sponsored projects effort to his/her DC.  In addition, faculty members must also be aware of committed effort of individuals assigned to his/her sponsored projects. Certifiers:

  • must be aware of his/her level of committed effort to sponsored projects;
  • note voluntary uncommitted cost sharing either in the actual effort column of the effort report template or in the ERS Notes box;
  • review the effort form to make sure the percentages correctly represent the covered individual’s effort based on salary charged to the award;
  • communicate any significant changes in level of sponsored projects effort to his/her DC;
  • have knowledge and understanding of committed effort for individuals assigned to his/her projects; and
  • review and certify effort reports.

 

Access to the Effort Reporting System

The Effort Reporting System (ERS) is a web-based system.  Access for administrators is primarily managed by the Effort Reporting CA.  However, the system also allows individuals designated by the Effort Reporting CA as DCs to assign Pre and Post Reviewers and, in some cases, Certifiers.  

The Effort Reporting System Access Request Form must be completed by  the operations manager or lead administrator and approved by the Effort Reporting CA prior to the assignment of an administrative role in ERS.  Prior to requesting access, the employee must complete Labor Distribution, Cost Transfer Principles, Principles of Effort Reporting and Effort Reporting System training. 

Access is periodically monitored by the CA.  Additional access monitoring must be completed by the Department or SubDC, as appropriate, when promotions, transfers and/or terminations take place.    

Logging On to ERS

Logging on to ERS can be accomplished via the Yale Administrative Links website: http://adminlinks.yale.edu/ or the Effort Reporting website: http://grants.yale.edu/financial-mgmt/effort-reporting.

Note:  If logging on to ERS from an off-campus location, a Virtual Private Network (VPN) connection is required.

Completing The Certification Process

The tasks below support the effort reporting process and are described in greater detail in the Effort Reporting System – User Guide located on the effort reporting website.  DCs should consider establishing timelines and expectations in their departments in order to ensure the effort reporting process described below is completed in a timely fashion.

TASK 1:  Assignment

Prior to Pre Review is the review and/or assignment of the effort report to the appropriate certifier.  The ERS defaults to the covered individual as the certifier of his/her own effort report form unless the assignment was changed in a previous effort reporting period. This assignment may or may not be appropriate for the subsequent effort reporting.  Faculty members (individuals where the job code = FAC), must certify their own reports; therefore, the certifier assignment for a faculty member should not (and due to a system restriction, cannot) be changed. 

Assignments can be updated by either the DC or the SubDC.  Upon completion of this task, the DC and/or SubDC should notify Pre Reviewers to proceed with Task 2.   

TASK 1a:  View Read Only Effort Forms

The Departmental Coordinator (DC) and the SubDepartment Coordinator (SubDC) have the ability to view effort reports that did not generate for covered individuals in the department (i.e., home organization) and have charges against awards and/or projects owned by the department (award owning and project owning organization as defined during setup).  The ERS provides the capability for the DC or SubDC to enter comments on the line owned by the organization.  This feature proactively assists home departments in the completion of the certification process. 

TASK 1b:  Identify Faculty That Have Left The University

Prior to a faculty member’s departure from Yale, all requisite effort report forms should be complete.  If the procedure for collecting forms prior to departure was not followed, the Department Coordinator should contact the departed faculty member to collect a signed Effort Report Form template and continue to follow the procedure for collecting forms prior to departure.  If the Department Coordinator is unable to collect the signed Effort Report Form, the Department Coordinator should communicate this matter with the Central Administrator.

TASK 1c:  Notify Certifiers of Open Effort Period

In order to prepare certifiers for the open effort period, Department Coordinators are encouraged to provide information regarding the effort report certification deadline, the University’s policy on effort reporting, and the Effort Reporting Pocket Guide. Sending a notification ahead of Pre Review also helps identify individuals that may be traveling or have left the University.  A sample email is provided in the procedure Appendix. 

TASK 2:  Pre Review

Prior to beginning Pre Review, the Pre Reviewer should ensure proper certifier assignments by reviewing the certifiers listed in the Pre Review worklist.  If any certifier assignment seems incorrect, the Pre Reviewer should assist the DC and/or SubDC by notifying him/her that a change in certifier is needed. Conducting Pre Review prior to financial statement review meetings held with faculty can help initiate an “effort portfolio” conversation.  In addition, the meeting’s agenda should include a discussion regarding the proper execution of the certification task. 

Pre Reviewers should identify early in the process those effort report forms that require a payroll change.  Adding missing accounts to the effort report form and/or working directly with a certifier to provide instruction on how to modify the Actual Effort percentage(s) keeps the certification cycle moving forward.  Pre Reviewers should escalate any known issues to the Department Coordinator, Division Head or Central Administrator.

TASK 3:  Certification

Certifiers should verify, prior to reviewing and subsequently certifying an effort form, the effort commitment to the sponsor by reviewing the proposal and/or progress reports, as well as the award document.  This effort commitment is the basis for charging salary to an award. 

Department Coordinators and/or Pre Reviewers are encouraged to plan financial review meetings with certifiers that coincide with the effort certification cycle. 

The DC’s weekly evaluation of the certification completion status of effort reports for any open period is necessary to assist in meeting the certification deadline. 

TASK 4:  Post Review

Post Review is not required when the certifier makes no changes to the effort report.  If a certifier makes changes to the Actual Effort and proceeds with certification, Post Review is required.  The Business Office employee responsible for completing Post Review will receive an automated email notification that Post Review is required.   Post review requires either a labor transfer to reallocate effort consistent with certification or, sometimes, requires a recertification based on a labor transfer that has been posted against a previously certified effort report.

When a certifier enters a Note and does not change Actual Effort, the Post Reviewer will receive a system generated email message.  The Post Reviewer should review the note and take appropriate action. 

Task Summary Matrix

Task

Description

Department/Sub Department Coordinator Action/Resolution

Preparation

Review the list of individuals generated in the system; identify missing forms.

Refer to the Effort Report Template section

1

Assignment

Assign Pre Review and Certifier roles, identify alternate organization assignments, and communicate with other Coordinators in home v. charging assignment situations. 

1a

View Read Only Effort Forms

View effort forms for individuals that are outside of the home department.  Make comments in the form(s) or communicate to the assigned Pre Reviewer as appropriate.

1b

Identify FacultyThat Have Left Yale

If the effort report form template was completed prior to the individual’s departure, follow the instructions above in this procedure.

When certification was not obtained prior to the faculty member’s departure, the DC should contact the departed faculty member to collect a signed Effort Report Form and continue to follow the instructions above in this procedure.

1c

Notify Certifiers of The Open Period

Communicate to certifiers that the effort period is open, provide associated deadlines and instruction.

2

Pre Review

Reviews the Critical List items to quickly resolve labor suspense; determine if a payroll reallocation is necessary; works with the Certifier to indicate Actual Effort, uses Add Account as necessary,  and reconciles the payroll distribution as part of the Post Review process (refer to the ERS User Guide). 

3

Certification

Monitor certification progress using the reports available in the ERS Reporting module. If the certifier has not responded to email or refuses to certify for reasons (unrelated to effort report percentages), escalate to the Division Head.  

4

Post Review

Post review requires either a labor transfer to reallocate effort according to certification or, sometimes, requires a recertification based on a labor transfer that has been posted against previously certified effort.

 

Monitoring The Certification Process

The following SAMPLE monitoring matrix is a tool the DC may want to consider using in order to ensure the timely certification of effort reports.  If utilizing such a matrix, timeframes should take into consideration, among other factors, volume and faculty calendars.  Note: Effort reports not reviewed and certified in accordance with University policy and processes could indicate the need to evaluate effort reporting business processes in the department.

Sample Monitoring MatrixPeriod Range (# of Days) or Day

Activity

Dependent Activity

0 – 15

DC or SubDC runs both of the Comprehensive Status Reports to view forms pending Pre Review

Task 1, 2

0 – 15

DC or SubDC completes forms [in the system] signed upfront by faculty that have left Yale and forwards a copy of signed report to OSP. Or, communicates to Central Administrator that assistance is necessary.

Task 1b

0 – 15

DC or SubDC prepares and distributes reports for individuals identified in Preparation task

Preparation

30

DC or SubDC runs both of the Comprehensive Status Reports to view forms pending Pre Review

Tasks 1, 2

31 – 45

DC or SubDC runs both of the Comprehensive Status Reports to monitor forms pending Certification; DC reminds certifiers during routine financial review meetings/provides an additional follow-up (timed after the CA notification).

Tasks 1 – 2

CA notification

31 – 45

Certifier analysis

None

46

DC or SubDC provides an additional follow-up with the certifiers (timed after the CA notification). 

CA notification

46 – 60

DC or SubDC monitors progress daily and escalates to the DH as necessary.

Tasks 1 – 2

60

   

61 – 70

DC or SubDC monitors Post Review progress and ensures payroll cost transfers are submitted to reconcile as necessary.

Tasks 1 – 3

 

If at any time during the certification cycle Pre Review or Certification cannot be performed, the DC should seek the assistance of the DH or the CA to resolve the underlying issue. 

Note:  SubDC should provide a status to the DC prior to escalation to the DH. 

 

Notifications During The Certification Cycle

Pre Reviewer and Certifier notifications are dependent upon form status; form status is a system-driven field updated as an effort report moves through the certification process.

The Central Administrator provides a calendar to DCs at the end of each year for the one following that specifies the dates notifications will be sent. 

Frequently Asked Questions

  1. How is “total effort” defined?

Total effort is defined as actual effort devoted to all the activities for which Yale compensates an employee for their appointment.

For faculty at Yale, 100% effort is the total time spent conducting University business regardless of the number of hours worked and includes teaching, research, clinical, administrative, and public-service activities.  Most ladder faculty generally have responsibilities that would preclude them from devoting 100% of their time to sponsored activities.

For non-professional staff positions, 100% effort consists of total hours worked including overtime.

  1. Can a faculty member who is working part-time at Yale use his/her uncompensated time to write and submit a Yale proposal?  

Yes.  For example, a Senior Research Scientist whose salary and corresponding effort is reduced from a 100% FTE to a 75% FTE due to a reduction in funding, may use the uncompensated time to prepare and submit proposals to sponsors.

  1. Who are “covered individuals”?

Anyone who has committed effort to a sponsored project (excluding fellowships) or is paid by a sponsored project at Yale must have his or her activities certified in an effort report; thus, that person would qualify as a “covered individual” for whichever period(s) they perform sponsored activities.

  1. When is it necessary to make changes to an Effort Report?

The percentages in the Payroll Percentage Column [of the ERS effort report] are provided for informational purposes only.  They represent the distribution (averaged over the reporting period) of the covered individual’s compensation among the listed sponsored projects and other activities.  That distribution may or may not be consistent with the distribution of Actual Effort on the projects and activities and can be adjusted as appropriate. 

If the payroll percentages on the Effort Report do not correspond to the percentages of the individual’s actual effort for the listed projects or activities (or other projects or activities that may not be listed), the person completing the form should enter in the Actual Effort Percentage column the actual effort percentages on each listed activity (missing projects/awards should also be added and the percent effort indicated).

The payroll percentages pre-printed on effort reports may not always represent the effort devoted; they reflect the percentage of salary charged to each account averaged over the reporting period.  When certifying the effort report form, the criterion to be used is how the individual’s effort was expended for the reporting period ensuring that the effort devoted is not less than the salary charged.  Effort expended as voluntary uncommitted should be reflected in the Notes box.

  1. Can a previously certified Effort Report be changed?

Salary reallocations made as a result of the effort certification process must be made in accordance with University policies and procedures on salary reallocations and cost transfers.

Once certification of salary has been completed in ERS, only in rare circumstances will subsequent salary adjustments be permitted.  If it is necessary to adjust the salary charges for a previously certified effort period, documentation must provide a detailed explanation of the need for the salary adjustment and subsequent recertification.  This documentation must be approved by the PI and be submitted to OSP for approval.  If approved, a recertification of the effort period may be required.

  1. For someone working on multiple sponsored projects, how should committed effort on a sponsored project be documented if paid for by the University (cost shared)?

Sponsored project effort not compensated by an award but committed as part of the proposal and subsequently awarded is a financial responsibility of the University.  In order to fulfill this responsibility, a cost sharing account must be created when the award is first received and salary charged as effort is expended.  The business office must follow-up with OSP to determine the status of the cost sharing account.  Labor schedules must be maintained in order to appropriately charge subsequent salaries to the cost sharing account.

  1. If I worked on one or more sponsored projects and did not charge salary to any of them, do I need to submit an ER?

Depending on the circumstances, there are situations when an ER is not generated and committed effort was devoted to a sponsored project.  In such situations, the responsible operations manager or lead administrator must go online to generate an effort report using a template: Effort Report Form template.  Instructions for completion are located here: 1315 FR.01 Effort Report Instructions

  1. What if I need to start my research and expend effort and incur costs on an award prior to receiving a fully executed contract, grant, or cooperative agreement?

For situations where an award is delayed, contact OSP to determine if an At-Risk Account is appropriate to request/create.  No work for an award should begin until such determinations are made.  Remember, At-Risk Accounts are subject to compliance requirements contained in Guide 1304 GD.01 At-Risk Accounts.

  1. What if my effort on a particular grant changes over time or is significantly different from committed effort?

It is the PI’s responsibility to obtain University (Chair and OSP) and sponsor prior approval for absences greater than 3 months or significant (25% or more) reductions of effort of the PI or others named in the award notice (check sponsor specific terms and conditions and sponsor policy manuals).  Salary charged to an award that is greater than the effort devoted must be adjusted.

  1. How is “cost sharing” defined?

Refer to Policy 1306 - Cost Sharing on Sponsored Projects for additional information on Cost Sharing.

  1. How should salary over a sponsor imposed salary rate cap be captured?

Irrespective of a sponsor imposed salary cap, all individuals impacted by the cap must devote the percent effort committed to in the proposal and subsequently awarded.  (Review Policy 1316 Effort Commitment: Managing Effort Associated with Sponsored Projects).

The difference between the reimbursed salary (“capped amount”) and the un-reimbursed must be accounted for in a “companion account”. (Refer to Procedure 1315 PR.03  – Salaries Above a Sponsor Imposed Rate Cap.) 

Note:  Carefully check award notices and referenced manuals/handbooks (both federal and non-federal) to determine if sponsors other than those applicable DHHS agencies apply a sponsor imposed rate cap.

  1. Why do graduate students’ Effort Reports often show 100% funded research when they also are being supported by a training grant?

2 CFR Part 220 – Cost Principles for Educational Institutions (OMB Circular A-21) and 2 CFR Part 200 (OMB Circular A-81) exempts effort devoted to training grants from the effort reporting requirement.  Therefore, if a graduate student is a trainee on a training grant and also supported on a research award, only the research award will appear on the Effort Report as 100%.  This means that 100% of the pay received for that reporting period was for the effort research award only.

However, if the graduate student is supported on a research award, a training grant and is also receiving compensation for teaching, both the compensation for teaching and the research will appear on the effort report.

  1. If a postdoc is both a PDA and a PDF during a reporting period, why is it the effort percentages do not include compensation received as a PDF? 

2 CFR Part 220 – Cost Principles for Educational Institutions (OMB Circular A-21) and 2 CFR Part 200 (OMB Circular A-81) exempts all remuneration paid on fellowships from the effort reporting process.  PDFs may also receive salary compensation for research services.  Refer to Guide 3550 GD.01 – Postdoctoral Fellows:  Sponsored Payments of Compensation, Augmentation of Stipends.

  1. In order to be paid summer salary when must I expend the effort?

In general, faculty receiving compensation for a 9-month academic appointment are permitted to devote summer effort on one or more sponsored projects in the period outside the academic year (June, July and August) and receive additional salary for that effort, subject to sponsor and University policy.  Faculty who receive summer salary from sponsored projects are required to certify to the effort devoted during the summer effort reporting period.  Effort expended during the academic year on a sponsored project cannot be applied to the summer effort reporting period.

  1. Can I claim three months of summer compensation and still have other summer activities?

If a faculty member has administrative or other non-research responsibilities during the summer period, they are precluded from devoting 100% effort to sponsored projects and thus from requesting 3 months of salary from those sponsored projects. 

  1. What are the special requirements for Veterans Affairs Connecticut Healthcare System appointments?

Refer to Guide 1411 GD.01 - Memorandum of Understanding Requirements: Faculty with both a Veterans Administration Medical Center and Yale University Joint Appointment. 

  1. What are the typical effort requirements for Career Development (K) Awards?

The NIH requires that total salary requested on a K Award be based on a full-time, 12 month staff appointment requiring the candidate to devote a minimum (usually 75%) of full-time professional effort to conduct health-related research.  The remaining effort may be devoted to clinical, teaching, or other research pursuits and activities consistent with the objectives of the award.  Please review the following NIH requirements:

<>·K Kiosk – Information About NIH Career Development Awards K Kiosk – Information About NIH Career Development Awards
 
  1. Should PI effort, devoted to other research awards and charged to the K award, be explained in the effort report Notes box? 
  • Salary for effort related to the career development plan is typically supported by the career development award funds to provide protected time (usually a minimum of 50% or 75% effort) required for the training experience; therefore, the effort report will reflect only the salary percentage charged specifically to the K award. For certification clarity, the administrator or the faculty certifier can enter a note to explain the concurrent effort being charged to other research awards that are in support of the career development plan.  But, this is not required.
    • Reminder:  the career development award proposal or annual progress reports must include references to all related research and clinical activities consistent with the objectives of the K award.
  1. Is a cost sharing account required to charge salary in excess of a Career Development (“K”) award program salary limitation in order to reflect effort that meets the minimum effort requirement? 
  • The maximum salary allowed to be charged directly to the K award is a limitation based on the program and/or the awarding institute or center and is not considered institutional cost sharing. 

However, in order to confirm that the minimum effort requirement has been met, the salary supporting the minimum percent effort requirement is normally charged to a linked* University source of funds for the amount in excess of the limitation. The designated project code of KSL must be utilized to identify K award salary in excess of the program limitation.  Since these dollars are not considered to be cost sharing they need to be properly identified so as to exclude them from the University’s F&A base calculation.  

  • Alternatively, where a linked account cannot be achieved (e.g., the CMHC staffing contract), a note can be entered in the effort report’s Notes box reflecting the percent effort being supported by unrestricted funds.  Illustrative Notes box example:  “The PI’s salary representing the 75% effort commitment to the K award exceeds the amount allowable by the sponsor and is additionally supported by the CMHC staffing contract.  Therefore, only 69% of the PI’s salary is directly charged to the K award and the remaining 6%, fulfilling the 75% commitment, is supported by XXXXX account.”

*The sponsored project associated with the K award is linked to a non-sponsored source of funds. 

  1. What happens if a PI refuses or otherwise fails to certify?

If the PI refuses to certify to his/her effort and salary on a sponsored project, then that salary must be removed.  A labor distribution adjustment needs to be created to move charges from the associated award(s) to a GA account, gift or other non-sponsored, unrestricted project account.

Failure to follow the provisions of Yale’s effort reporting policies and procedures may subject the individuals and departments responsible for the violation(s) to administrative and/or disciplinary actions in accordance with University disciplinary procedures.  Specifically, and without limitation:

  1. If Effort Reports are not completed and returned in a timely manner, salary costs associated with uncertified grant activity may be removed and charged to a departmental account;
  2. OSP may suspend submission of any new proposals on behalf of a noncompliant PI (or inclusion of a noncompliant researcher) in proposals until Effort Reports are up-to-date and properly completed and certified; or
  3. Certification of Effort Reports that are known at the time of submission to be materially inaccurate may expose the individual who completed the reports to personal disciplinary action.

Failure to complete required effort reports certifying that the work was performed may require the University to return the award to the sponsor.

Appendix

Sample Email to Certifiers – Announcing Effort Certification Cycle

To:  Department Certifiers

From:  Department Coordinator

Subject:  Effort Reporting Period is Open

“As a condition of receiving sponsored awards, the University must assure sponsors that the effort expended on their sponsored projects justifies the salary charged to those projects. In addition, the University must assure sponsors that the commitment indicated (including mandatory and voluntary committed cost sharing) in the proposal and subsequent award is met in accordance with the sponsor’s terms and conditions. The University provides this assurance by requiring periodic effort reports for each individual whose salary is charged to one or more sponsored projects and/or cost sharing accounts during the effort reporting period…” ~ Yale Policy 1315

The effort reporting period covering [insert dates] is now open.  Certification is due [insert date]. 

As a certifier of effort reports, you will be receiving an automated system email once the business office has completed a preliminary review.  The email message contains a link to the Effort Reporting System (ERS).  ERS is also available through the University portal under Tools & Services > Research.

 Information about the effort certification process can be found in the pocket guide (Yale Principles of Effort Reporting and Yale’s Effort Reporting System); and, there is a Tutorial available in the application’s menu bar once signed into the system.