- Responsible Office: Office of Grants & Contracts Accounting and Effort Reporting, University Controller’s Office
- Current Approved Version: 03/07/2022
- Policy Type: Administrative
Policy Statement and Purpose
As a recipient of sponsored funding, including federal funding, Virginia Commonwealth University (VCU) is responsible for complying with the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In order to comply with the Uniform Guidance cost principles pertaining to personnel expenses (2 CFR 200.430(i)), VCU utilizes the Employee Compensation Compliance (ECC) system.
The guidelines that follow are meant to assist all personnel involved with the research and administration of sponsored programs, in effectively implementing a sound internal control environment over personnel expenses. Noncompliance with this policy could lead to significant risk exposure to VCU and the removal of personnel expenses on sponsored awards. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.
Table of Contents
|Who Should Know This Policy|
|Policy Specifics and Procedures|
All individuals directly involved with sponsored award administration and research, and clinical activities are responsible for knowing these guidelines and familiarizing themselves with its contents and provisions. This includes; principal investigators, key personnel, fiscal and grant administrators, effort coordinators and other research personnel.
The Office of Grants & Contracts Accounting and Effort Reporting (G&C) is responsible for interpreting this policy. Please direct questions to the Effort Reporting Team at (804) 828-8104 or email@example.com.
The effort shown on an effort report which has been certified by the employee or by a person with first-hand knowledge of the work performed.
An individual who has first-hand knowledge of work performed on specific projects, or of clinical activity, and who certifies the effort attesting to the fact that the work was performed.
Refers to VCUHS Effort Reporting Categories and Definitions below.
- Clinical Practice and Administration - Patient care activities including inpatient services, outpatient services, other types of clinical activities, any of which generate a professional fee is charged including services provided under a clinical contract.
- Supervision of Interns and Residents - Effort expended by faculty physicians in the supervision and training of residents and interns including resident recruitment and resident training program administration. Do not include time related to any billed clinical services (regardless of location) or supervision of residents at the McGuire VA Hospital.
- VCU Medical Center Administration - All time expended by faculty in supervising hospital personnel, providing medical direction, participating in hospital committee activities, participating in hospital managerial or administrative activities.
- Other Educational and Administrative Activities - Time expended by faculty in educational activities related to the education of medical students (pre interns and residents) and education of fellows and post-doctoral (post intern and residents) or non-department, non-hospital, and non-institutional activities.
Work or the proportion of time spent on any professional activity (activity done for, or at the request of VCU, as a result of a person’s position held at VCU) and expressed as a percentage of total time. Total effort for an employee always equals 100%, even if the appointment is less than full time. Further, effort is divided into the following sub-categories:
- Sponsored Effort – Includes conducting or administratively supporting programs for research, instruction, or other purposes that is funded by an external entity.
- Non-Sponsored Effort – Includes university-funded research as well as activities like instruction, departmental research, proposal writing, public service and administration.
- Clinical Effort – (See definition above)
Employee Compensation Compliance (ECC)
ECC is a web-based technology that intuitively guides certifiers and administrators through the various facets of the effort reporting and certification process on a periodic basis.
Effort reporting is the method used to confirm to sponsors that the effort spent on a sponsored agreement reasonably reflects the salary and wages charged to that agreement. An effort certification is used to collect said data and is an “after the fact” reporting of activities for which the employee was compensated by the institution.
A document outlining a faculty member’s labor distribution; including sponsored, non-sponsored, and clinical effort for a designated period of time. When sponsored and/or clinical effort is present, these documents are reviewed and certified by the faculty member to confirm that the labor distribution outlined reasonably corresponds to the work performed for the designated period.
Payroll Cost Transfer (PHARED)
An expense that is transferred from one index to another, after the expense was initially processed in Banner on the original index. A PHARED refers specifically to a cost transfer involving labor distribution and personnel expenses.
A document outlining the payroll and corresponding effort for non-faculty employee’s (support staff) on a sponsored project. These documents are reviewed by the sponsored project’s Principal Investigator and certified to confirm that the payroll & effort for each employee reasonably reflects their work on the project.
An externally funded program under which the university is obligated to perform a defined scope of work according to specific terms and conditions and within budgetary limitations. These programs are to be budgeted and accounted for separately from other activities. Sponsored programs include grants, contracts, cooperative agreements, clinical trial agreements, Intergovernmental Personnel Agreements and other awarding instruments supporting research, instruction, public service, and clinical trials.
VCU Research Core
VCU is pleased to support a number of Core Laboratories which facilitate a wide variety of research in the biomedical, life, physical, and social sciences. Some of these core laboratories are institutional, while others are associated to specific schools, programs or departments. However, all are available to all VCU researchers, typically on a fee-for-service basis. See a full listing here.
VCU Centers and Institutes
Virginia Commonwealth University’s Centers and Institutes (ICs) work across disciplines and research to create new knowledge. Representing some of the most cutting edge investigations taking place in the world today, the VCU’s ICs conduct unique investigative collaborations to add value to the university in terms of intellectual power, resources and collaborative potential, extramural funding and resource development. See a full listing here.
Maximum Sponsored Effort
VCU Principal Investigators (PIs) and Faculty should not have more than 95% of their total effort directed towards sponsored programs. This applies to 12-month, 9-month, and 3-month appointments. Having a 95% cap on sponsored effort provides room for a PI and/or Faculty member to capture their non-sponsored activities, which may include one or more of the following: teaching, proposal writing, committee participation, departmental duties, and any other administrative responsibilities associated with their appointment and/or department.
In limited circumstances, it may be considered reasonable for a PI or Faculty member to have more than 95% of their effort directed towards sponsored programs. However, PIs and Faculty with 95% or more sponsored effort are subject to a regular compliance review conducted by G&C.
Certification of Effort Statements
When certifying an effort statement, faculty must review their labor distribution across sponsored (including cost share), non-sponsored and clinical activity (if applicable), on their effort statement and determine if those percentages reasonably correspond to their work performed (effort) during the effort period. Variances up to, and including, 5% between labor distribution and certified sponsored effort are deemed reasonable and may be certified as such.
Any variance that is over 5% will either require re-certification within the 5% variance, or the processing of a payroll cost transfer (PHARED) in order to correct the employee’s prior labor distribution.
Certification of Project Statements
Every period of performance (semester based for Monroe Park Campus, semi-annual for MCV Campus), Principal Investigators must review the amount of salary and effort charged to their grant(s) for the related support staff (non-faculty). If the amount charged to the grant(s) reasonably reflects the work performed in the designated period, PIs are required to certify the statement. In the event a PI determines that an employee’s salary/effort charged to the project should have been significantly more/less, they are to contact their department administration and request a payroll cost transfer (PHARED) be completed to adjust for that amount, prior to certifying the project statement.
Certification of Effort by Proxy
In the event an employee is unable to certify their own effort statement, this responsibility can be completed by another individual. However, said individual must have direct knowledge of the employee’s performed work (effort) across the entire period of performance. This includes sponsored, non-sponsored, and clinical effort.
Designees for Project Statements
In certain and rare circumstances, a designee may be assigned to certify a project statement(s) on behalf of a PI. Prior to approval, the PI must show a demonstrable need for said designee, with the explanation being reviewed and approved by the corresponding Department Chair, and Director of G&C. Moreover, all designees will be required to complete the PI Effort Reporting training.
Once a designee has been approved and assigned in ECC, they will have the authority to certify project statements on behalf of the PI. However, it is incumbent upon the department to ensure that the PI is still reviewing said statements in some capacity prior to their certification. Lastly, project statements with approved designees will be subject to an annual internal review by G&C.
Timely Certification of Effort & Project Statements
Upon receiving an effort or project statement for certification, faculty and PIs are given 60 days to certify in compliance with this policy. After 60 days have passed, if the statement has yet to be certified, it is considered past-due and escalation procedures within G&C will be followed.
Roles and Responsibilities
Office of Grants & Contracts Accounting and Effort Reporting (G&C)
- Maintain the ECC system
- Communicate any changes in policy, procedure or schedule as it pertains to these guidelines and the effort reporting function to all stakeholders
- Regularly communicate with effort coordinators and department administrators to ensure that effort statements are certified and processed timely
- Conduct routine reviews of ECC for highly sponsored PIs and Faculty, and take corrective action as necessary
- Review their own effort reports, and when applicable, those of others working on their awards for reasonableness
- Certify their own effort reports, and when applicable, project statements of their awards within 60 days of receiving the statement
- Ensure that the work performed on their awards is consistent with the committed effort
- Review and adjust effort commitments upon the awarding of proposals to ensure that their sponsored effort does not exceed 95%
- Review the personnel expenses on their awards in order to identify any effort-related changes that need to be made
- Monitor the effort of key personnel on their awards to ensure that their committed effort is being met
Faculty (Non-PIs Working on Sponsored Research)
- Faculty should monitor their own effort commitments, and ensure all of their activities, sponsored and non-sponsored, are represented on their effort statement
- Timely certification of their own effort reports
Department & Effort Coordinators
- Review existing commitments, project periods, new proposals, and existing awards to ensure effort commitments are reasonable, accurate, and are being met
- Communicate with certifiers during the effort certification period to ensure all effort statements are certified timely
- Process all effort statements for the department
- Review salary charges with PI/faculty member and ensure labor distribution is up to date and includes all of an employee’s activities
There are no forms associated with this policy.
- VCU Policy: Minimum Effort for Principal Investigators and Key Personnel on Sponsored Programs
- VCU Policy: Cost Sharing
11/18/2021 New Policy
There are no FAQ associated with this policy.