The Office of Sponsored Programs at Harvard has created a school-wide policy on Effort Reporting to guide the process of effort certification on sponsored projects. To comply with these guidelines, Harvard has deployed the web-based system, ecrt, to serve as the new tool to facilitate the salary certification and effort reporting process. Certification of salaries for all exempt staff, non-exempt staff, graduate research assistants, postdoctoral fellows, etc. whose salaries are supported in whole or in part by federal funds is carried out quarterly, according to the procedures described here.
The Principal Investigator (PI) of each sponsored project bears the ultimate responsibility for spending awarded funds appropriately, and he or she is uniquely qualified to certify the effort of his or her employees on that project. Every quarter, he or she must review the project based certification in ecrt for each of his/her projects and certify that:
- each person paid by a federal sponsored project devoted the indicated proportion of his or her time and effort to that project,
- the work occurred during the indicated time period, and
- any transfers or adjustments of salaries to that project reflect the actual effort performed by the employee on that project.
Completion and Certification of Quarterly Project Effort Certifications (QPEC)
Quarterly Project Effort Certifications are generated for each federal award that has non-faculty salary charges at the subactivity level. Each quarterly certification includes all non-faculty personnel who were charged to the account during the quarter. The quarterly certifications follow the fiscal year: July-September, October-December, January-March, and April-June. Once released to the PI, the certifications should be completed within 30 calendar days.
The PI of an award or part-of account is expected to sign his/her Quarterly Project Effort Certification(s). The certifier is attesting that he/she has sufficient technical knowledge and/or is in a position that provides for suitable means of verification that the work was performed. There are circumstances when it may be appropriate for the PI to delegate this responsibility to another individual, a designee, associated with the project.
The PI must login to ecrt quarterly to sign the certifications himself or herself. Certifiers of Quarterly Project Effort Certifications are expected to review the payroll distribution percentages on the effort report and determine whether those percentages reasonably correspond to the individual’s actual effort on the project. Variances up to 3% of the individual’s total salary for each award listed 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. (For example: a certification with a charge to an award for 40% of an individual’s time in that quarter can be approved provided the actual effort is between 37% - 43%, +/- 3%).
FAS PI Designees: All PIs are required to certify their Quarterly Project Effort Certification(s). In certain circumstances, the PI can delegate this responsibility to another individual with first-hand knowledge of his or her sponsored award(s). The individual who signs the effort certifications must attest that the salaries charged and effort expended reasonably reflect work performed on the project and that the signer has sufficient technical knowledge and/or is in a position that provides for suitable means of verification that the work was performed.
If a situation arises where a designee is appropriate, the department should complete and submit the Request for Delegation of Authority for Quarterly Project Effort Certifications form via email to Christyne Anderson PRIOR to the corresponding certification period. The request form must have a start and end date detailing the duration of the delegation and the designee named must be able to defend the salary allocations. Please include a brief justification along with the request form. Please note: Laboratory Directors and other departmental administrative staff do not normally have sufficient first-hand knowledge of research personnel activities to defend salary allocations to internal or external auditors, nor is it appropriate for a non-PI researcher to certify his or her own salary report.
Recertification of Quarterly Effort Certifications
Certifications will automatically be re-opened and need to be re-certified by the PI or designee if a payroll salary journal is posted to a sponsored award after the certification has been signed and the journal creates a variance above the 3% (non-faculty) threshold. Recertifications should be completed within 21 calendar days after the e-mail is sent indicating that the certification is re-opened.
A full version of the University-wide Effort Reporting Policy can be viewed on the OSP website.
Questions or concerns about effort reporting should be addressed to Christyne Anderson, firstname.lastname@example.org or (617) 495-1837.
How do I avoid issues during my review?
Since auditors consider frequent salary transfers at an institution to be an indication of poor grants management, it is best to place salaries correctly on each grant the first time, and to minimize the movement of people among different grants. Administrators responsible for appointing staff are encouraged to meet with PIs on a regular basis, reviewing project assignments and funding sources prospectively for each employee and correcting appointments to ensure that salary transfers are not needed in subsequent months. In the event that a transfer is necessary, it is good practice to create a note on the effort statement in the system, to explain the circumstances that led to the transfer. Note that all transfers of salaries onto federal sponsored awards must comply with Harvard's Cost Transfer Policy.