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.