Title: Effort Reporting
Effective date: December 26, 2013
Responsible Official: Assistant Vice President for Research
Responsible University Office: Office of Research Administration
Revision History: August 13, 2020
Related legislation and University policies: 2 CFR 200.400
Review Period: 7 years or as needed with the revision of Federal Regulations
Date of Last Review: August 13, 2020
Relates to: Faculty, Staff, and Students
Statement
Case Western Reserve University requires all faculty, staff, and students who work on sponsored projects to verify that the time they have reported and charged to these sponsored projects is accurate. This time will be reported as a percentage of the overall faculty, staff, and student effort, which encompasses all of the activities assigned to the position. The time of the research staff reported and charged on sponsored projects will be certified by the principal investigators.
Applicability
This policy applies to all individuals with roles on CWRU-administered sponsored projects, whether the primary appointment of the individual is established through the University or through one of its affiliated hospitals.
Definitions
Effort is defined as the total scope of responsibilities expected of the appointment, regardless of the actual numbers of hours worked. Expectations of the position are generally established as part of the appointment process.
The effort report is the means by which an individual documents the proportion of time allocated to each of the activities with which s/he is involved. This becomes the official verification that the salaries charged to sponsored projects are consistent with the reported effort.
Cost-sharing occurs when the University bears a portion of the costs of a sponsored project (e.g., committing a personnel at no cost to the project.) Mandatory cost share is required by the sponsor as a condition of award. Voluntary Committed cost share is not required by the sponsor but is pledged in a proposal budget or budget justification. If the budget is so approved, the cost-sharing becomes mandatory. Voluntary Uncommitted cost share is also not required by the sponsor but also not pledged anywhere in a proposal budget or budget justification. Although a commitment may not appear specifically in a budget, if it is mentioned anywhere in the proposal and subsequently approved, the cost-sharing becomes mandatory.
Purpose and Reason
Effort reporting is a federal requirement. As a recipient of federal funds, the University requires certification of effort to provide a reasonable basis for distributing salary charges among direct activities (e.g., sponsored projects, instruction, clinical activity, and administration.) Other government and private sponsors provide significant funding to the University, and the effort reporting system assures these sponsors that salaries and wages are properly expended and consistent with the effort devoted to the projects they have sponsored. All faculty and staff involved in certifying effort must be aware that severe penalties and funding disallowances may result from inaccurate, incomplete, or untimely effort reporting.
Guidelines and Expectations
Activities to be used as the base for calculating percentages of effort should include all research, teaching, administration, clinical responsibilities, and any other activity that has been established as being within the scope of responsibility for the CWRU and/or affiliated hospital appointment, regardless of the source(s) of compensation for this set of activities. These responsibilities will normally be defined as part of the appointment process.
The compensation base that is used in related documents, such as grant proposals, should be the compensation that is established for the defined set of activities of the appointment, and does not include independent consulting performed outside of the parameters of the appointment, nor should it include incentives or bonuses received for clinical performance.
Effort reports must account for all activities as assigned to the individual by the appointing institution(s). Percentages are determined based on a reasonable estimate of activities, since research, instruction, and clinical activity are often difficult to delineate clearly. Percentages are derived on the basis of the number of hours an individual usually devotes to work on a weekly basis.
Process
The effort report form must be completed by the individual whose effort is being reported. In exceptional circumstances, such effort reports may be completed by a responsible person with access to verifiable information on how the individual's effort has been expended.
Mandatory or voluntary cost-sharing must be reported.
The total of the individual effort percentages must be equal to 100%.