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Rice University Policy No. 304

Effort Reporting

Policy Overview  

Rice University is required to comply with federal regulations regarding effort certification of individuals paid from, or contributing to, sponsored programs. Effort reporting is required of all individuals who are either paid from any sponsored projects (whether or not sponsored with federal funds) or who commit time as cost sharing to such sponsored projects. Individuals working as volunteers without compensation are exempt from effort reporting requirements.

Rice University has established an effort reporting policy and procedures to ensure that salaries and benefits charged to sponsored programs, or contributed as cost sharing, are reasonable, allocable, allowable, consistently treated, commensurate with effort expended and confirmed in a timely manner based on appropriate documentation.

Implementation  

The Office of Management and Budget (OMB) Circular A-21, "Principles for Determining Costs Applicable to Grants, Contracts and Other Agreements with Educational Institutions," establishes the principles that colleges and universities must follow for expenditures of federally sponsored program funds and offers several acceptable alternatives for effort reporting. Rice University has chosen to require effort reporting for faculty and professional staff no less frequently than every six months. In addition, the university requires an annual certification that graduate student payments for services performed, including charges to sponsored agreements, are reasonable in relation to the work performed by the student.

The federal government acknowledges that effort reporting is not a precise exercise. The section in OMB Circular A-21 on compensation for personal services states: "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."

Confirmation of effort means that: the work has been performed; the percentage of effort attributed to activity on each sponsored program during the reporting period is reasonable in relation to 100% of total effort for all activities for which the individual is paid by Rice during the period; and the charge to each award is appropriate in relation to the work performed.

"Total effort" is defined as all professional activity for which the University employs an individual, whether on a full-time or part-time basis, including students who are working as teaching or research assistants. For reporting purposes, effort is calculated in percentages, not hours, with the total of all Rice effort equaling 100%. For faculty, total effort includes, but is not limited to, teaching, office hours, student advising, research activities, committee service, departmental meetings, professional development and community service at Rice or to Rice. Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. Specific short-term assignments, such as teaching a continuing education course, that are not a routine part of an individual's employment and are compensated separately, are not considered part of "total effort" and are excluded from the effort reporting requirement.

If actual effort applied during a project period is significantly less than what was committed in the award, approval of the reduction in effort may be required from the sponsor or awarding agency. (For instance, OMB Circular A-110 states that recipients are required to report deviations from budget and program plans, and request prior approvals for budget and program plan revisions, if there is an "absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.")

Roles and Responsibilities  

The Vice President for Finance, together with the Vice Provost for Research, is responsible for establishing and updating Rice's effort reporting policy.

Deans, Assistant Deans and Department Chairs are responsible for understanding and ensuring compliance with Rice University's effort reporting policy and procedures. This includes providing oversight, effective processes and controls and problem resolution.

Department administrators are responsible for reviewing effort, salary and labor charges, as recorded in accounting reports and on time allocation forms, on a regular basis and submitting documents to make changes or corrections if they are needed. Each university department has oversight responsibility to ensure that confirmations are complete, accurate, and timely.

Research and Cost Accounting in the Controller's Office (RCA) is responsible for preparing and distributing effort confirmation reports semiannually for faculty and staff, and annually for graduate students. RCA is also responsible for providing training on effort certification policies and procedures and for overseeing the effort reporting process.

Each principal investigator (PI) is responsible for ensuring compliance with this policy for his or her awards, including awards on which the PI serves as a Co-PI. The PI is responsible for certifying his or her effort report in a timely fashion. The PI should ordinarily sign the effort confirmation form for each person paid from or contributing to sponsored projects, including staff, graduate students, undergraduates and post-doctoral fellows. If the PI is not able to sign the form, a designated employee who has a suitable means of verification that the work was performed may sign.

Failure to Comply  

Since failure to follow federal effort reporting rules could result in expenditure disallowances and penalties or fines levied against Rice University, the University will take corrective action in the event that this policy and associated procedures are not followed, including, but not limited to, disciplinary action. To ensure compliance with effort reporting policy and procedures, Rice may suspend grant submissions from the involved individuals until delinquent PI or Co-PI effort reports are properly completed and certified, unless an exception for extenuating circumstances is approved by both the Vice Provost for Research and the Vice President for Finance.

Reports that are not properly completed, certified and returned to RCA by the scheduled effort reporting deadline will be considered overdue. Reports will be considered delinquent if not properly completed and certified within 30 business days from the date of the scheduled effort reporting deadline. During this 30-day period, RCA will endeavor to notify department chairs, deans and PIs about issues with effort reports that have not been timely or properly completed, certified and returned to RCA within the reporting deadline.

Policy No. 304
Issued: January 26, 2009

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Procedures:  

Additional information about effort reporting procedures and links to federal circulars are available from the Research and Cost Accounting website at http://www.professor.rice.edu/professor/Guidelines_and_Procedures.asp#EffortReporting