GAP NO. 200.170
Effort Reporting
I. GENERAL
This procedure describes how Duke defines effort and the reporting requirements of OMB Circular A-21. We have two types of effort, University Effort (i.e., Institutional Base Salary (IBS)) – The amount of time spent ONLY on University activities, including, research, instruction, and administration and Total Professional Effort (TPE) which represents time spent on ALL Duke-related activities, including PDC and Durham VA effort.
What should be included in Sponsored Research Effort:
Regardless of where effort is expended (office, home) or when (after hours, on vacation, on weekend), these items should be included in your sponsored research effort.
Effort on current Federal Grants or contracts (e.g., NIH, NSF, or DOD), effort on current non-federal research projects (e.g., a foundation grant or industry clinical trial), writing progress reports, lab meetings, attending a scientific conference, or reading scientific journals.
What should NOT be included in Sponsored Research Effort:
These activities must be funded at an appropriate level by your department or discretionary account.
Instruction and administration, which includes writing grant proposals (including competing renewals), department meetings, supervising students in non-grant related activities, interviewing students, participation on Institutional Committees such as search committees, Institutional Review Board (IRB) or Institutional Animal Care & Use (IACUC).
Effort reporting at Duke University uses two options to meet the requirements of OMB Circular A-21. The circular requires the University to document the distribution of effort and salary that its faculty and employees expend either directly or indirectly in support of federally funded projects.
The two effort reporting options are as follows:
- Monitored Workload (Plan Confirmation) - Used for all monthly paid faculty and staff members. (Sub system is maintained to generate quarterly certifications of effort and distribution).
- Personnel Activity Reporting - used for all bi-weekly paid employees (the employee time card is the certification of effort and distribution).
The monitored workload system and Personnel Activity Reports interface with the HR/payroll system to accumulate payroll data. Standards for acceptable methods of plan-confirmation are listed in Section IV of this document.
II. MONITORED WORKLOAD SYSTEM (EFFORT REPORTING) – FOR EXEMPT EMPLOYEES
A. |
Overview |
There are two types of Monitored Workload Effort Certification reports for exempt employees.
At the end of each of the first three quarters of the fiscal year, effort certification Periodic Notice Statements are prepared for each faculty/staff member and distributed to each department or school business office. These statements serve as a notification of how the individual's effort is being distributed so that it can be modified if necessary. At the end of each fiscal year, effort certification reports are prepared for applicable faculty and staff members. These annual certification reports show the actual salary, supplemental pay distributions and the percentage of annual effort for the entire fiscal year. Each employee is required to certify that the actual effort expended per the report is correct or, if incorrect, indicate the correct percentage of effort expended on the various activities. If there are significant changes of effort percentages, redistribution of salary may be required.
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B. |
Quarterly Periodic Notice Statements |
After the September, December and March pay cycles, when the monitored workload file has been updated with any necessary changes for those pay cycles, the two types of Periodic Notice Statements (regular salary and supplemental pay) will be generated and sent to departments for review. Regular (base) salary distribution calculation: The weighted average percentage for an activity is calculated by adding the percentages for each month's regular salary for an activity and dividing the sum by the number of months the individual received a regular salary payment during the period. The denominator is always the number of months the individual received a regular salary payment through the month of the report. Even if salary was not charged to an activity each month, the denominator is still the total number of months the individual received a regular salary payment. This methodology is appropriate for a staff or faculty member regardless of the term of appointment. Supplemental pay distribution calculation: The weighted average percentage for an activity is calculated by adding all supplemental payments during the period for the activity and dividing this amount by the grand total of all supplemental payments for the period. Thus, the percentage for an activity is the total cost charged to an activity as it relates to the grand total of supplemental payments for the period. The Office of Sponsored Programs distributes the Quarterly Periodic Notice Statements to University departments and maintains control logs documenting the distribution. The department distributes the statements for review to the applicable monthly paid staff and faculty members or to a person having first hand knowledge of the effort expended. Any errors must be corrected by preparing and submitting a Cost Distribution form through iForms, see GAP 200.150, Cost Transfers on Sponsored Projects. The statement does not need to be returned to the Office of Sponsored Programs; after the statement has been reviewed, the department may either file or dispose of the statement.
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C. |
Annual Certification Reports |
After the June monthly pay cycle when the monitored workload file has been updated with any necessary adjustments, two types of annual certification reports (regular salary and supplemental pay) are generated for certain faculty/staff members. The distribution percentages are calculated for the Certification Reports the same way they are calculated for the Periodic Notice Statements. The Office of Sponsored Programs distributes the reports to University departments and maintains control logs on the reports distributed. A copy of the General Department Administration Activities checklist and the Detail of Effort Supporting Duke Hospital check list is included for those individuals who have expended effort supporting general departmental operations or Duke Hospital. The departmental administrator distributes the reports and check lists to the applicable faculty/staff member for review and signature. If the staff or faculty member is not available, a person having first hand knowledge of the effort expended by that individual can verify and sign the report and complete the check list. The information can be verified with absent individuals by telephone or e-mail if necessary. If the actual annual percentage of effort is different from that shown on the report, enter the actual percentage in the certified annual effort column. The total percentages must equal 100%. A Cost Distribution form through iForms must be submitted correcting the error or errors in accordance with GAP 200.150, Cost Transfers on Sponsored Projects. The certified reports and completed checklists must be returned to the departmental administrator responsible for the control of these reports. The departmental administrator is responsible for forwarding them to the Office of Sponsored Programs by the designated date. The Office of Sponsored Programs will log in the certified reports and check lists, review all changes of effort expended, prepare transfers of costs for significant changes (based on the Cost Distribution form through iForms submitted by the department), and process them for the second preliminary general ledger closing. All certification reports, check lists and transfers of cost, are maintained by the Office of Sponsored Programs. |
III. NON-EXEMPT EMPLOYEES: PERSONNEL ACTIVITY REPORTING SYSTEM / EFFORT CERTIFICATION REPORTING
Duke University is responsible for obtaining certifications on staff effort for salaries charged directly on sponsored projects. Please refer to GAP 101.5, Time Reports- General Section III Biweekly Payroll for the specific procedures.
The general procedure for certifying effort for non-exempt employees is outlined below.
The payroll labor distribution system produces a preprinted time report for each employee for each biweekly time period. The employee completes the time report by entering hours worked (including all applicable premium hours) and not worked (but for which payment is being claimed, e.g., vacation, sick leave, etc.) and certifies the accuracy of the data.
The person who has first hand knowledge of all work performed by the employee reviews the report, certifies the correctness of the hours recorded, and certifies that the distribution of wages for the period represents a reasonable estimate of the actual effort expended. When distribution corrections are necessary, submit a Biweekly Direct Code Charge Report to reflect the correct distribution, in accordance with GAP 100.523, Time Reports - Biweekly Direct Code Charge Report. Corrections made after the pay period is closed are done by completing a Cost Distribution form through iForms, in accordance with GAP 200.150, Cost Transfers on Sponsored Projects. This process reconciles the Personnel Activity Reporting System with the cumulative payroll information recorded in the general ledger.
Each department accumulates the time reports for their employees, retains the yellow copy, and sends the originals to Corporate Payroll Services for processing. The yellow copy of the timecard is retained to compare to the actual charges as reflected on the Accounting View of Payroll reports. This detects keying errors and reduces the possibility of someone falsifying the time report after it has been approved.
Note: The distribution on the time report is the latest distribution available at the time the primary and secondary time reports are prepared and sent to the departments. If a Staff Change Form has been submitted subsequent to the distribution of the time report, and prior to the close of the pay period for which the time reports represent, write "STAFF CHANGE FORM SUBMITTED" across the distribution codes to indicate knowledge of the change that has been submitted.
IV. STANDARDS FOR ACCEPTABLE METHODS OF PLAN-CERTIFICATION (PER OMB CIRCULAR A-21)
Plan-Confirmation
Under this method, the distribution of salaries and wages of professorial and professional staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity, updated to reflect any significant changes in work distribution. A plan-confirmation system used for salaries and wages charged directly or indirectly to sponsored agreements must meet the following standards:
(a) A system of budgeted, planned, or assigned work activity will be incorporated into the official records of the institution and encompass both sponsored and all other activities on an integrated basis. The system may include the use of subsidiary records.
(b) The system will reasonably reflect only the activity for which the employee is compensated by the institution (compensation for incidental work described in subsection a need not be included). Practices vary among institutions and within institutions as to the activity constituting a full workload. Hence, the system will reflect categories of activities expressed as a percentage distribution of total activities.
(c) The system will reflect activity applicable to each sponsored agreement and to each category needed to identify F&A costs and the functions to which they are allocable. The system may treat F&A cost activities initially within a residual category and subsequently determine them by alternate methods as discussed in subsection b(2)(c).
(d) The system will provide for modification of an individual's salary or salary distribution commensurate with a significant change in the employee's work activity. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term, such as an academic period. Whenever it is apparent that a significant change in work activity which is directly or indirectly charged to sponsored agreements will occur or has occurred, the change will be documented over the signature of a responsible official and entered into the system.
(e) At least annually a statement will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed, stating that salaries and wages charged to sponsored agreements as direct charges, and to residual, F&A cost or other categories are reasonable in relation to work performed.
(f) The system will provide for independent internal evaluation to ensure the system's integrity and compliance with the above standards.
(g) In the use of this method, an institution shall not be required to provide additional support or documentation for the effort actually performed.
V. INDEPENDENT INTERNAL EVALUATION – ANNUAL EFFORT CERTIFICATION PROCESS
In accordance with OMB A-21, j. (10), an independent internal evaluation of the effort reporting system’s integrity and compliance is conducted on a regular basis and reported to the University’s Research Costing Compliance Officer.
| GAP History | |
| Issued: | September 1994 |
| Revised: | October 2001 |
| Revised: | May 2002 |
| Revised: | July 2002 |
| Revised: | May 2003 |
| Revised: | September 2004 |
| Revised: | July 2006 |
| Revised: | February 2008 |