The federal government (per the Uniform Guidance Subpart E §200.430) sets requirements for internal controls over certifying time expended on sponsored projects and requires that salaries paid fully or partly from federal sponsored awards be “certified” in a process that is distinct from appointment and payroll procedures. This payroll certification process is known more generically as “effort reporting.”
Uniform Guidance Section §200.430(c) and Harvard Policy stipulate that:
- Salaries paid must “reasonably reflect the activity for which the employee is compensated by the institution….”
- An “after-the-fact confirmation” of activity must be performed, so that the certification is based on actual, not proposed, costs.
- Activities must be “confirmed by responsible persons with suitable means of verification that the work was performed.”
- Pay must be allocated proportionally among multiple activities in which the employee is involved.
- Salary certification “may reflect categories of activities expressed as a percentage distribution of total activities,” since different institutions define a “full workload” differently.
As with the rest of the University, FAS employs eCRT for its effort reporting needs. To comply with these guidelines, the University has adopted three salary certification programs, one for faculty academic year salary, one for faculty supplemental salary, and one for all other employees.
Effort Reporting for individuals who do not receive salary from Harvard
eCRT is designed for individuals to certify that the percentage of their Harvard salary allocated to each research project accurately reflects the percentage of effort expended on each project. If you are an individual who does not receive salary from Harvard, but you are expending effort on Harvard research, eCRT is not used. We are currently not required to certify effort at Harvard University for individuals who do not receive salary from Harvard.
A few Frequently Asked Questions:
Q: What is considered a ‘reasonable estimate’ with regards to effort reporting?
A: Sponsors recognize that the activities that constitute effort are often difficult to separate. Per OMB Uniform Guidance effort certification must often rely on a reasonable estimate of effort, and when estimating, a degree of tolerance is appropriate.
- For faculty and all annual certifies, variances of up to 5% of total salary for each award listed are allowable and do not require an adjustment or recertification. Variances over 5% for each award should be corrected, in compliance with the Cost Transfer Policy, prior to final approval of the certification.
- For all quarterly individuals, variances of up to 3% of the individual’s total salary, 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.
Q: Why do I see negative effort on a statement?
A: In many cases, negative effort is a result of journals being incorrectly coded, usually regarding the period of performance. These journals are usually processed based on the G/L transaction date rather then what was actually earned during the quarter. As we cannot certify negative effort, if the charges that appear on a statement are incorrect, a journal should be processed to make the appropriate adjustment.
Q: When would it be appropriate to manually certify a statement?
A: In general manual certification of effort statements is discouraged and whenever possible statements should be electronically certified by the appropriate statement owner.
However, under the circumstances noted below the use of manual certifications is either necessary or acceptable. Note that in all situations backup documentation is required and must be uploaded to ecrt.
- When the certifier has left the University and can no longer login into ecrt or for some other reason is unable to certify electronically. (Sign PDF with no changes to the printed percentages.)
- When the need for a journal is identified that will not be processed in time to meet the deadline. Please note that in this instance a cost transfer form may also be required. (Manually change the PDF effort percentages to what they will be once the journal is posted.)
- When non-IBS activity is charged to a certifiable object code that is skewing the effort. An example is when extra compensation or a TA payment is paid in a salary object code. (Manually change the PDF effort percentages to exclude the non-IBS payments.)
Q: When would it be appropriate to void statements and mark them as “No Certification Required”?
A: There are two main scenarios in which it may be appropriate to void a statement.
- The statement is $0 and 0% ( Usually the result of miscoded salary that hit a statement that was subsequently removed)
- The salary for each individual on the statement is < = $250 or < = 3% of their salary