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Administrative and Financial

Effort Reporting and Summer Salary Policy

Scope

Students, Faculty, Staff

General Policy Statement

As a recipient of federal funding, Syracuse University (the "University") is required to comply with the United States Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance") as well as other federal regulations for sponsored awards. Under the applicable federal regulations, the University must certify that faculty, student, and staff salaries charged to sponsored awards correspond with the effort expended on all activities performed in connection with the award.

Reason for Policy/Purpose

controls for certifying and reporting efforts expended by faculty, students, and staff on sponsored awards. This Policy sets forth those internal controls and provides guidance to University personnel on effort reporting.

Policy

  1. Effort Reporting and Certification Process

    The University utilizes a retroactive effort reporting system to certify that the salaries charged, or costs shared to sponsored awards, are reasonable and consistent with the work performed. Through the effort reporting and certification process, the University ensures that charges to a sponsored award or institutional account were fairly made, accurate and recorded in a timely manner. The process also allows the University to document that the actual effort exerted on a sponsored project is certified and appropriately charged to the sponsor when considered in the context of all institutional activities.

    For faculty, students, and exempt staff, effort is to be reported as a percentage of the total institutional effort for which the individual is compensated, exclusive of non-institutional base activities (e.g. overload, extra service activities, or other non-base compensation).

    Certifications must be performed on a semester basis (fall, spring, and summer).

    Ordinarily, individuals should perform their own effort certifications. As required, based upon facts and circumstances, a Principal Investigator (PI), Project Director (PD), or other individual having suitable means of verification may be designated a certifier for an individual. Individuals or their designees should consult with the Office of Sponsored Accounting Central Administrator regarding special circumstances.

    For non-exempt staff, the payroll timesheet, signed by the employee and the employee's supervisor who has a suitable means of verification that the work was performed, will serve as the effort certification. The effort certification should be completed by the communicated certification period deadline. The individual performing the certification should consult with the Office of Sponsored Accounting Central Administrator regarding special circumstances.

  2. Effort Reporting and Certification Responsibilities

    Effort reporting responsibilities include:

    1. PI /PD and Faculty Members

      • Understand their own, as well as their staff members' (non-faculty personnel), levels of effort committed, charged, and reported on all applicable awards;
      • Review individual effort, initiate corrections if necessary, and electronically certify the effort;
      • Communicate significant effort changes to the department administrator / prereviewer effort coordinators;
      • If necessary, present a reasonable formal written request to the Office of Sponsored Accounting (OSA) to delegate certification responsibility to another individual who has sufficient knowledge and/or is in a position that provides for suitable means of verification that the work was performed:
      • Routinely review salary charges on awards with the grant manager, identify any effort-related changes, and communicate these changes to the administrators so posting of corrections can be made, if needed;
      • Re-certify the report if effort changes are made after a statement has been certified. The certification is considered the signature.

    2. Department Administrator

      • Monitor effort commitments, salary charges, and cost sharing on all applicable awards;
      • Communicate to the central sponsored programs offices, the Office of Sponsored Programs (OSP) and/or OSA any changes that require sponsor notification and/or approval;
      • Review salary charges with PI/faculty member and post any salary distribution updates and/or corrections in an timely manner;
      • Review effort certifications for accuracy during the pre-review period and communicate significant changes in effort to sponsors;
      • Update effort commitments to reflect the new effort commitment when changes in effort are approved by sponsors.

    3. Office of Sponsored Accounting - Central Administrator

      • Monitor effort certifications for completion after the effort certification period is opened to Campus;
      • Review, and approve or reject PI delegate requests received for alternate signers on faculty effort certifications;
      • Maintain the University's effort reporting policy;
      • Provide effort reporting training and guidance, and oversee University-wide compliance with the effort reporting policy;
      • Manage the technical aspects of the electronic effort reporting system.

  3. Effort Reporting Percentages

    Certain conditions allow for special considerations and possible limitations in determining allowable personnel compensation costs under federal awards. Charges to federal awards may include reasonable amounts for activities contributing and directly relating to work under an agreement, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, developing and maintaining protocols (human, animals, etc.), managing and securing project-specific data, coordinating research subjects, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences.

    Total Institutional Effort:

    1. For effort reporting purposes, total institutional effort is 100% effort, regardless of an employee's appointment (e.g., 0.5 FTE, 0.625 FTE, or 1.0 FTE). No individual may commit more than 100% institutional effort or be compensated at a rate that would exceed their annualized institutional base salary.
    2. For faculty and exempt staff, effort is to be reported as a percentage of the total institutional effort for which the individual is compensated, exclusive of non-institutional base activities (e.g. overload, extra service activities, or other non-base compensation). Institutional effort is a set of activities or functions for which an employee is paid an institutional base salary. For faculty members receiving academic year compensation, institutional effort ordinarily includes instruction, research, and service. For academic administrators, institutional effort will also include administrative duties.

    Acceptable Variance Range:

    1. Uniform Guidance Section 200.430 states, "It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to federal awards for Institutes of Higher Education (IHE), a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected." As such the University has established an acceptable variance range of +/- 3% of actual effort charged to effort anticipated to be charged.
    2. Certifiers of Semester Effort Certifications are expected to review the payroll distribution percentages on the effort report and determine whether those percentages reasonably correspond to the individual's actual effort on the award. Variances up to 3% of the individual's total salary for each award listed for the period being certified are allowable and do not require an adjustment. Variances over 3% should be corrected, in compliance with the Cost Transfer Policy, prior to final approval of the certification. (For example: a certification with a charge to an award for 40% of an individual's time in that semester can be approved provided the actual effort is between 37% - 43%, +/- 3%).

  4. Summer Salaries and Effort Reporting

    The effort reporting system applies to faculty, students, and staff summer salaries and other charges as follows:

    1. Subject to a sponsor's policies and departmental or unit approval, faculty members with 8.5-month academic year appointments may participate in sponsored projects during the summer and be appropriately compensated for their effort at a rate not to exceed their rate of pay in effect at the time the work is performed.
      • When any faculty member's summer appointment is at 100% of their institutional base salary, they may only engage in activities that directly benefit the award(s) providing the compensation.
    2. The maximum summer sponsored project compensation ordinarily cannot exceed the amount derived from 3.5 months payment at 95% of base salary.
    3. Individuals engaged in summer teaching, administrative or other non-sponsored activities are precluded from receiving the maximum summer sponsored projects compensation. In such cases, summer compensation must be adjusted proportionately to ensure that maximum summer compensation from all sources does not exceed the rate of pay in effect at the time work is performed and the sponsor receives the proportionate benefit of effort funded during the period. The individual's home department is responsible for enforcement of this Policy.
    4. Sponsored effort committed during the academic year cannot be deferred or "charged" to the summer period.
    5. It is expected that faculty members receiving summer salaries from a sponsored project will ordinarily perform such work at the site of the activity.
  5. Enforcement

    Implementation of this policy will be evaluated periodically by the University's Office of Audit and Management Advisory Services to ensure the system's integrity and compliance with the above standards.

    Faculty, students, and staff who consistently fail to abide by effort reporting requirements, despite repeated education and training, may have certain privileges restricted by the Vice Chancellor and Provost.

Appendices (as applicable)

  1. Prodedures

    The University Comptroller's Office is responsible for establishing procedures necessary to comply with the effort reporting policy and communicating the procedures to the University community. The procedures will be consistent with the standards for the plan confirmation method presented in the Uniform Guidance Subpart E 200.430.

    For more information about effort reporting procedures visit:

  2. Definitions

    Cost Shared - Any award costs that are not borne by the sponsor. Cost sharing of effort is the provision of faculty and/or staff time and related fringe benefits that were committed and provided in support of an award but are paid for by other sources of funding. Costshared effort in excess of the commitment made in the proposal does not have to be identified or certified.

    Designee - Authorized delegation of certification responsibilities on a specific sponsored award to another individual for effort reporting.

    Effort - The amount of time spent on a particular activity. It includes the time spent working on a sponsored award in which salary is directly charged or contributed (cost share).

    Effort Reporting - The mechanism used to provide assurance to federal or other external sponsors that salaries charged or cost shared to sponsored awards are reasonable in relation to the work performed. Effort reports are also referred to as certifications.

    Institutional Base Salary - An individual's institutional base salary is the annual compensation that the applicant organization pays for an individual's appointment, whether that individual's effort is spent on research, teaching, service, or other activities. Base salary excludes any income that an individual may be permitted to earn outside of the duties to the applicant organization.

    Key Personnel - The principal investigator and other individuals who contribute to the scientific development or execution of an award in a substantive, measurable way, whether or not they request salaries or compensation.

  3. Forms

    Forms can be located on the Office of Sponsored Accounting website at http://comptroller.syr.edu/bfas-forms/.

  4. Other Related Policies and Documents

  5. Frequently Asked Questions

    Please visit the Office of Sponsored Accounting website at http://comptroller.syr.edu/resources/effort-reporting/effort-reporting-faqs/ for answers to some frequently asked questions about effort reporting.

Date: June 26, 2014
Amended:April 25, 2016


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