Sponsored Programs Finance Administration and Compliance

For proposal purposes, the requested salary support should normally be determined by multiplying the proposed level of effort by the individual’s Institutional Base Salary. This determines the allowable charge to the project. In no event should the requested salary support exceed this amount. Levels of effort proposed in any sponsored project application should be consistent with the actual effort that each individual is expected to expend on the project during the relevant project period(s). The proposed level of effort must be expressed in accordance with sponsor requirements. Some sponsors require that the level of effort be proposed in terms of person months (e.g., example, three person months of a 12-month appointment). Other sponsors expect the proposed level of effort to be expressed in percentage terms (e.g., 25% of total effort).

Example: Dr. X, a calendar year employee, has 50% of his total university effort of 100% available for research. If the proposed level of effort for Project Y is 25% (three months of a 12-month appointment), and Dr. X’s Institutional Base Salary is $100,000, normally the requested salary support would be $25,000 per year. Dr. X then has a balance of 25% of total University effort to be used for other research related activities.

Example: A PI on an AY appointment at a salary of $63,000 would have a monthly salary of $ 7,000 (one-ninth of the AY). 25% of AY effort would be 2.25 AY month. The budget figure for that effort would be $15,750 (25% of total AY salary). Two Summer Salary months for this PI would be $14,000 (equivalent to two-ninths of AY salary). Two summer months would be 66% of the three month summer term.

Example: A PI on a CY appointment at a salary of $ 72,000 would have a monthly salary of $6,000 (one-twelfth of total CY salary). 25% of CY effort would be 3 CY months. The budget figure for that effort would be $18,000 (25% of total CY salary)

Anytime that payroll does not accurately reflect how the employee spent his or her time on the certified effort report, an adjustment to the effort and payroll distribution is necessary. OMB Circular A-21 recognizes that activities that comprise an individual's total effort (teaching, research, service, administration, etc) are often difficult to separate and that "an exact assessment of factors that contribute to costs is not always feasible, nor is it expected." Certification must rely on a reasonable estimate of effort during a specified time period, and when estimating, a degree of tolerance is acceptable and appropriate.

Requests for potential revisions to sponsored project effort are to be submitted to ORSP for approval. ORSP will determine if the request is reasonable and allowable.

Any individual who works any portion of his or her time on sponsored projects or activities, whether compensated (funded) or uncompensated (cost share) by that project, is required to certify effort (signature). OMB Circular A-21 requires that the person certifying the effort report must have "suitable means of verification that the work was performed”. In most cases, that would be the employee and the employee's direct supervisor.

In the employee's absence, the principal investigator for a specific project may also certify the effort of the employees working on the project. The PI must be able to verify that persons paid on their sponsored projects actually performed the work and must be in a position to provide verification of the effort certified. Personnel paid via timesheets provide the required certification of their effort through completion and signature of timesheets, which require supervisor signature and approval. Signed timesheets provide auditable documentation of an employee's certified effort. Penalties and funding disallowances may result from inaccurate, incomplete, or untimely effort reporting.

ORSP issues effort reports three times per year; at the completion of the fall semester, at the completion of the spring semester, and at the completion of the summer term.

Effort reporting is a federal requirement. UL Lafayette must assure federal, state and other sponsors that the assignment of effort and associated salary costs to projects they sponsor is fair, consistent, and timely. Certified effort reports provide auditable documentation to confirm that personnel did commit the level of effort outlined in the award (actual effort). All faculty and staff involved in certifying effort must be aware that penalties and funding disallowances may result from inaccurate, incomplete, or untimely effort reporting.

In compliance with the Office of Management and Budget (OMB) Circular A-21, Section J.10, UL Lafayette is required to develop a mechanism to confirm how individuals actually expend effort during a specified time period on externally sponsored activity. The ORSP effort report form documents an individual’s proportion of effort (funded and cost share) committed to each sponsored project expressed as a percentage of total University effort. The individual then documents the actual effort expended on each project. This becomes the official verification that the salaries charged to sponsored projects are consistent with the reported effort. This percentage should also be consistent with projected and actual effort reported on the Office of Academic Planning’s Faculty Workload forms (especially, Section II. Research/Scholarship, C. Grants and Contracts). Faculty and staff who work any portion of his or her time on sponsored projects or activities whether compensated (funded) or uncompensated (cost share) by that project, is required to certify effort.

There are two types of effort reports issued at UL Lafayette.

1. UL Lafayette Office of Academic Planning and Faculty Development administers a Faculty Work Load Form. Employees must account for all effort for which the University compensates the individual. This includes all effort expended on sponsored projects, administration, business development, instruction and non-sponsored scholarly activity, and other activity. It does not include effort for which the employee receives compensation directly from another entity (e.g., outside consulting work) or incidental work for which supplemental compensation (i.e., extra state/overload compensation) is paid. This report allows an employee to distribute his % of duties throughout various activities for a total of 100%.
   
2. The UL Lafayette Office of Research and Sponsored Programs (ORSP) sends employees with sponsored research commitments an effort report specific to those projects. Effort reported to ORSP should be consistent with projected and actual effort reported on the Office of Academic Planning’s Faculty Workload forms (especially, Section II. Research/Scholarship, C. Grants and Contracts).

Effort committed to sponsored programs comes in two forms, funded effort and cost shared effort.

1. Funded Effort: Personnel salary charged to sponsored/paid by sponsored research agreements or university research projects, commensurate with the direct effort provided to the project.
2. Cost Shared Effort: The portion of effort toward a project or program that is not reimbursed by the sponsor. Cost sharing is a commitment of institutional funding or resources for which the University is not compensated by the sponsoring agency. There are three types of cost sharing:
   1. Mandatory Committed: cost sharing that is documented in the proposal and agreed to in the sponsor's awarding documents.
   2. Voluntary Committed: cost sharing that the sponsor did not require, but the proposal nonetheless included, and subsequently became a condition of the award.
   3. Voluntary Uncommitted: cost sharing that the University expended on the project, but was not required by the sponsor. This type of cost sharing occurs when effort exceeds pay.

Only mandatory committed and voluntary committed cost sharing must be tracked and reported to the sponsoring agency. Voluntary uncommitted cost sharing need not be reported to the sponsoring agency; however, all effort (whether cost shared or direct charged) must be tracked and reported to the University even if the effort is voluntary uncommitted cost sharing.

Total University effort (“total effort”) is the professional activities for which an individual is compensated by the University, totaling 100%. Typical activities include research, teaching, administration, and any other activity that has been established as being within the scope of responsibility. The denominator of the effort percentage must always be total University effort, irrespective of the total number of hours worked during the effort reporting period.

Example: If a faculty member works an average of 50 hours per week during an effort reporting period and works an average of 10 hours per week on a particular sponsored project, the correct effort percentage for that project would be 20% (10/50=.20) of total University effort.

1. Appointing of Faculty & Staff: Employment terms are established including number of months and salary base.
2. Preparing the Proposal Budget: Effort commitment is proposed.
3. Accepting the Award: Effort commitment is finalized.
4. Charging Salary: Effort is charged in a real time manner consistent with activity.
5. Certifying Effort: Effort is attested to after activity has occurred. ORSP issues effort reports requesting certification of effort on sponsored projects.

Effort is defined as the total scope of responsibilities expected of the appointment, regardless of the actual number of hours worked. Effort is the time spent on any activity by an individual, expressed as a percentage of the individual’s total University effort. Effort does not include activities such as consulting that are conducted outside the terms of employment or faculty appointment.