Part III - UNM Finance: Practical Applications

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Standard Accounting Resource Manual (SARM)

MSC 0000 00
1 University of New Mexico
Albuquerque, NM 87131

Why Certify Effort

Effort reporting is a federal requirement. To receive federal funding, institutions must maintain an accurate system for reporting the percentage of time (i.e. effort) that faculty and other exempt employees devote to federally sponsored projects (see OMB Circular A-21, Cost Principles for Educational Institutions - Compensation for Personal Services).

In addition, federal and state agencies, private foundations, organizations, and private industry provide significant funding to enable the University to conduct research, public service, and training projects. UNM’s effort reporting system provides the principal means for certifying that the salaries and wages charged to sponsored projects are consistent with the effort committed.  All faculty and other employees involved in certifying effort must understand that severe penalties and funding disallowances could result from inaccurate, incomplete, or untimely effort reporting.

The University of New Mexico requires semi-annual effort certifications to track the effort the faculty and other exempt employees who have been paid from and/or committed to sponsored project effort. Each University department has the primary responsibility to ensure compliance. If effort is not properly certified, salary charges must be removed from the sponsored project.  The certification process is completed in two stages; pre-review and certification.  The pre- review is completed  by department personnel  within 30 days and the certification process is completed by the PI within 30 days. All needed labor redistributions should be completed during the pre-review stage.  The Pre-review must be completed prior to certification of effort.  The pre-reviewer receives email notifications throughout the pre-review stage.  Emails are sent to the PI’s at the beginning of the certification stage and weekly thereafter.  Reminder and delinquent notifications are sent for those records that are not completed within the 30 day period.

OMB Circular A-110, located in PDF format at:

 http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a110/2cfr215-0.pdf  requires grantees to obtain the sponsoring agency’s approval in writing if the PI or key personnel specifically named in the Notice of Grant Award (NGA) will:

  • Withdraw from the project entirely;
  • Be absent from the project during any continuous period of 3 months or more; or
  • Reduce time devoted to the project, by 25 percent or more, from the level approved at the time of award.

This rule applies to all federal grants unless waived in writing by the sponsor.  The sponsoring agency must approve any alternative arrangement proposed by the grantee, including any replacement of the PI or key personnel named in the NGA. The effort commitment approved by the sponsor at the time the award is issued is considered the threshold against which reductions of 25% or more need to be requested and approved by the sponsoring agency. In order to be in compliance, the PI should compare the original commitment in the award document against actual grant effort on the Effort Certification form.