Effort Reporting: Semi-Annual Payroll Verification

Effective July 1, 2016, and in accordance with federal regulations pertaining to effort certification on federal awards (Uniform Guidance Subpart E §200.430), MBL effort reporting procedures have changed.  Sponsored project personnel are no longer required to certify effort on a monthly basis. The new semi-annual payroll verification process will require that Principal Investigators certify effort for all project personnel every six months.  Please note that the process for PI-review of project expenditures and correcting project salary cost allocations (and any applicable cost corrections) will continue on a monthly basis in consult with the appropriate Research Administrator.

Principal investigators will have 30 days to complete their semi-annual payroll verification statement for the 6-month time period beginning either January 1 thru June 30 or July 1 thru December 31 of each year.

 

Effort Reporting at the MBL: Semi-Annual Payroll Verification

Procedures 

Time of Award:  Changes to project budget categories (in compliance with sponsor guidelines) are communicated to OSP by the research administrator to ensure accurate loading of the project budget in Navision.

Monthly Review:  Each month, Financial Services generates and submits a grant summary report to the Research Division, Research Administrators and Education Division support staff for review with principal investigators. The grant summary report includes payroll charges for all salaried staff on the project.  Upon release of the report, the PI and RA review salary charges, remaining effort forecast, and communicate errors/changes to OSP and Financial Services.

Semi-annual Certification:  PIs must certify accuracy of the effort for all project salaries charged to a sponsored project on a semi-annual basis for the following fiscal periods:

  • January 1 through June 30
  • July 1 through December 31

In the month following each six-month fiscal period, Financial Services will generate a payroll verification statement which OSP will release to the PI (with copy to the RA) for certification and electronic signature.  Upon completion, the documents must be submitted electronically by the indicated deadline. By certifying the payroll verification statement, the PI 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.  An example of a payroll verification statement can be found below.

PIs are required to review certifications and determine whether the effort metrics reasonably reflect the committed effort expended and the work performed on each sponsored award and the aggregate effort associated with “all other activities” displayed on the certification.  PIs must complete the certification no later than:

  • March 1 (for the July – Dec. statement)
  • September 1 (for the Jan. – June statement)

Recertification: Certifications will be automatically re-opened and require recertification by the PI if a payroll salary ledger entry is posted to a sponsored award after the certification has been signed.  Recertifications must be completed within 30 calendar days after the notification date that certification is re-opened.

*Note that federal grant applications and performance reports require that effort be reported as person months.

Minimum Effort Threshold:  All PIs and key personnel identified on a sponsored project must have effort, if required by the sponsor. Committed effort can be charged directly to awards or to an identified non-federal cost center.

Specific to NIH awards the following clarification was published in 2003 regarding charging effort on federal awards: “ …the contribution of Key Personnel [must be] “measurable” whether or not salaries are requested.  Zero percent effort and “as needed” are not acceptable for individuals that the grantee identifies as Key Personnel.

 

Example of an MBL Semi-Annual Payroll Verification Statement (document sent via AdobeSign)


For more information regarding policy and procedures contact:

Donna Dickerson

Director of Sponsored Programs and Research Administration

e:  ddickerson@mbl.edu or p:508-289-7301