Federal regulation (Uniform Guidance §200.430 Compensation - personal services) requires that an entity receiving federal funding to have adequate documentation to support that compensation charged to federal grants is reasonable for the work performed. Effort reporting is UCLA’s method of complying with the requirement, providing reasonable assurance that the charges are accurate, allowable, and properly allocated. Individuals who committed effort on a federal or federal flow-through funds are required to certify that the compensation charged, or cost shared by the institution is reasonable in relation to the effort allocated to that project. Incomplete or improper reporting of effort is a compliance violation that could result in audit disallowances and/or withholding of future federal research funding.
Please see quick reference guide on how to access effort reports to certify.
The Certifier must have first-hand knowledge of the work performed. If an individual does not have first-hand knowledge of the work performed, whether they are an employee in an administrative role or involved in the research, they are not authorized to certify.
- Principal Investigators and other faculty in Professorial, Professional Research, and Management titles who are paid on or have commitments to work on federal or federal flow-through funds are required to certify their own effort since they are in the best position to understand how they are spending their time in support of the various activities in which they are engaged.
- Principal Investigators should also certify for employees that they have primary oversight of, given the fact that they have first-hand knowledge of the work performed.
- Self-certification for all staff is an option. However, each department sets their own self-certification policies based on their department's culture.
If you are uncertain who should certify the effort report, please consult with your ERS Coordinator or ERS Support.
If the Paid Effort % to Certify reflects the correct figures and it doesn't match with the Payroll %, the effort report can be certified but it will show a status of Certified/AdjustReqd. In this case, payroll transfers should be submitted to make them match. Once the payroll transfer is processed and a “late pay” is issued (during 1 of the 3 payroll cycles) and picked up by ERS, the report's status should change to “Certified.” If the payroll transfer was processed correctly and the Payroll % still does not reflect the correct figures, contact ERS Support for assistance.
Note: An active employee should always have access to their effort reports. The PI or Co-I should have access as well if he/she is linked as the Managing Investigator in Account/CC table in OASIS.
When a PI terminates his/her appointment before certifying his/her staff's effort reports, we recommend one of the following actions:
- If the PI is still affiliated with UCLA and has access to ERS, please have him/her logon to the system and certify his/her reports. Bear in mind that if they are accessing the system from off-campus, they will first need to logon to the UCLA network via VPN. Step-by-step VPN instructions and screenshots can be found at the Bruin Online website. Once they are connected to the UCLA network, then they can access the ERS website.
- If the PI no longer has access to ERS, you may send them a copy of the effort report requiring certification and have them reply with their certification. To do so, you may either use the “Send” function in the system (navigate to the desired report and click the “Send” button on the top right hand) or take a screenshot of the report and paste it in an email to them. In their response, they should verify/confirm the effort in the attached report is correct, or state what the correct effort should be, if any changes are required. (This email should be kept on file in your department as back-up documentation). Upon receiving the PI's “manual” certification, someone in your department, preferably the department chair or someone closely-related to the project, should log into the system and electronically certify the report on the PI's behalf. He/she should also provide an explanation in the “Comments” field that the PI has left the university but has manually certified via an email/letter that is on file with the department.
- If the PI is no longer reachable and option 1 and 2 above are not feasible, then the last option is to have someone here at UCLA with first-hand knowledge of the project and the effort worked to certify the effort reports. As with option 2, the individual certifying the report on behalf of the PI should provide an explanation in the “Comments” field, indicating that the PI is unavailable and that the person certifying on his behalf has first-hand knowledge of the PI's or employee's effort.
This status is often triggered when an effort report does not total 100%. An effort report that totals less than 100% is usually caused by unrecognized earnings. To see if a report has unrecognized earnings, select the “View Payroll Detail” option on the effort report. Typically, unrecognized earnings are payroll transactions that contain an account number or full accounting unit (FAU) that has not been defined in ERS. When ERS cannot identify a FAU on a payroll transaction, it cannot include the earnings in the effort report calculation because the system cannot properly categorize the earnings as belonging to a sponsored project or not.
Another situation when an effort report will have an Exception status is when a FAU on the report's total is a negative percent. This usually means a credit has been processed and there has been no debit to offset it. To fix this issue a payroll adjustment needs to be processed.However, there are other situations that can cause an effort report to go into an Exception status. In any case, a report with an Exception status cannot be ignored and requires some action. If you are having trouble certifying one of these reports, please contact ERS Support for assistance.
Example: A report has three FAU's at 33.33% each. The true rounded total would be 99%. Since effort has to be 100% for certification, the system will add a percent to the top FAU making it 34%. Subsequently, the report total will equal 100%. When a report's true total is 101%, the system will remove a percent from the top FAU to make the report total 100%.
However, the system will not use this rounding methodology when there are unrecognized earnings.
OMB Circular A-21, Section J-10, Payroll Distribution, General Principles, (c) states:
In the use of any methods for apportioning salaries, it is recognized that, 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.
At UCLA we have set the tolerance at ±5% of what is on the effort report. Although University policy allows for a 5% tolerance, we have to abide by the sponsor's policies and/or the award documents. If there are restrictions on the salaries/effort going over or under the budgeted amount, you should abide by those restrictions if it reasonably reflects the individuals effort. Then submit payroll transfers to reflect the correct figures if necessary.If the sponsor is flexible and there are no restrictions on the budgeted salary/effort changing, you do not need to adjust the report if it is within ±5% of what your adjustment was going to be. However, the tolerance does not apply when the exact effort is known. If the exact effort is known it should be reported accurately and the individual should be paid accordingly.
The 1% tolerance only takes effect when a LatePay (payroll expense transfer) is processed for effort reports with a status of Certified or Certified/AdjustReqd. The 1% system tolerance is different from the 5% tolerance. The 5% tolerance is a UCLA policy based tolerance which is in reference to how an individual's salary is distributed. The 1% tolerance is a system based tolerance that allows certain reports to change to or maintain their Certified status after payroll transactions have been processed.
If an effort report's status is Certified or Certified/AdjustReqd and a LatePay is processed that causes the Payroll % and Paid Effort % to Certify to be off by 1% on any given FAU, the report will change to or remain Certified.The 1% tolerance will help departments expedite their effort report certifications. When a payroll transaction has been submitted, the departmental ERS personnel can put the projected figures into ERS and have the report certified before the payroll transaction appears in the financial system. The effort report will not have to be re-certified if the figures are off by 1% due to rounding because the 1% tolerance will take effect and the report will show a status of “Certified.” However, if the figures are off by more than 1%, the effort report will re-open and will need to be re-certified.
If a PI worked on a federal project “without” salary, an effort report will not be automatically generated in ERS. Contact your department coordinator for help or ERS Support to generate a report for the quarter. Once a report has been produced, the ERS Coordinator who generated the report will notify you. Upon notification, you will need to enter the percent of effort in the “Paid Effort % to Certify [B]” column, add a statement in the comment box, and click save. Notify the PI so they may certify the report.