Why do I need to report and certify my effort?
Effort reporting is required, not just by USC policy but also by the federal government, under Uniform Guidance 2 CFR 200 Subpart E1 (formerly A-21 – Cost Principles for Educational Institutions). Effort certification demonstrates that salary charged to a sponsored project reasonably reflects effort performed on the project for the time period being certified.
Effort certification is a way for the government and other sponsors to verify that salaries charged to a project are for work done on that project.
Effort certification is required for every employee who receives a portion of his or her salary from a sponsored project or cost sharing account. You share in USC’s responsibility to report effort accurately and in a timely manner as do other faculty and staff. Inaccurate effort reporting or failure to comply with effort reporting policy may result in:
- financial penalties
- expense disallowances
- damage to USC’s reputation
- damage to your own reputation
Late effort reports may result in a spending freeze on the associated grant or contract. Following the frequently asked questions about effort reporting are several examples of faculty effort profiles and how to certify them accurately. For detailed instructions on how to use eCert, the university’s online effort certification system, please consult the General Information Document.
Who needs to certify effort?
All effort on grant, contract or cost-share accounts needs to be certified. All faculty and exempt staff are required to certify their own effort in eCert, USC’s online effort reporting system. The principal investigator (PI) is responsible for certifying the effort of his or her graduate research assistants. In certain cases, the PI can assign a delegate to approve graduate research assistant effort. Nonexempt, or hourly, staff and hourly faculty effort is certified biweekly through the university’s time-keeping systems (not the eCert system).
What does it mean to be a person with “suitable means of verification” for effort reporting purposes?
At USC, all faculty and exempt staff must certify their own effort. Since they performed the work, they are the most qualified to certify for themselves. For graduate research assistants, the principal investigator is the person with “suitable means of verification,” as he or she oversees the project and has the “direct technical knowledge of the work” being performed. The principal investigator may delegate the responsibility to certify for the graduate research assistants only to another researcher on the project who works with the student. Responsibility may not be delegated to an administrator unless he or she has direct knowledge of the work being performed.
Can my administrative assistant or department business officer certify for me?
No. You are the certifier and must certify your own effort. This is because you possess both direct technical knowledge of the project you are certifying and suitable means of verification that the work was performed. Administrative assistants or department business officers are not expected to have direct technical knowledge of the work being performed.
What are the penalties for not certifying my effort or falsely certifying my effort?
Inaccurate effort reporting or failure to comply with USC effort reporting policy may result in financial penalties, expense disallowances and damage to USC’s reputation or yours. Late effort reports, monitored through reporting in eCert, may result in a spending freeze on the associated grant or contract.
This may also result in disciplinary action for faculty, subject to the policies in the Faculty Handbook, and for staff, subject to the review of the associate senior vice president for Administrative Operations.
When is effort certified for 12-month faculty and exempt staff effort?
Twelve-month faculty and exempt staff certify their effort after each quarter, as described below. Certification is based on the average effort over the quarter.
- First Quarter (Q01) runs from July through September
- Second Quarter (Q02) runs from October through December
- Third Quarter (Q03) runs from January through March
- Fourth Quarter (Q04) runs from April through June
When is effort certified for nine-month faculty and graduate research assistants?
Nine-month faculty will certify their effort after each semester as follows:
- Fall Semester (S01) runs from August 16 to December 31.
- Spring Semester (S02) runs from January 1 to May 15.
If the faculty member has summer research supplement funding, then the Summer Semester must also be certified. Graduate research assistant effort must be certified on the same schedule. Certification is based on the average effort over the semester.
- Summer Semester (S03) runs for three months, from May 16 to August 15.