Compliance Team
Subrecipient Monitoring FAQ
The Federal Funding Accountability and Transparency Act (FFATA) was signed on September 26, 2006, and mandates reporting of Federal fund obligations that meet certain criteria.
The FFATA Sub-award Reporting System (FSRS) collects data from Federal prime awardees on sub-awards they make: a prime grant awardee will be required to report on its sub-grants and a prime contract awardee will be required to report on its sub-contracts.
The SPS Compliance Team, Subrecipient Monitoring group maintains Washington State University’s reporting account and is responsible for completing FFATA reporting for all eligible contracts and subawards.
Search for the award at https://www.usaspending.gov/search. All FFATA reports will be visible in the Award History section under the subaward tab.
If any obligations over $30,000 or deobligations are missing from the USA Spending report, please email sps.subawards@wsu.edu. Include the award number and subaward number(s) in your request.
Please keep in mind that Washington State University is required to report subawards that meet or exceed $30,000 in total obligated funding over the life of the award (including all amendments). This includes deobligations of any amount if the subaward exceeded $30,000 at any point. Subawards that have not exceeded $30,000 in obligated funding will not be reported and will not be visible on USA Spending.
Effort Overview
The effort reporting system was introduced several years ago as a result of requirements prescribed by the federal Office of Management and Budget in the OMB Circular A-21
The phrase “effort reporting” does not appear anywhere in the OMB Uniform Guidance. “Compensation for personal services” is where you look for guidance in OMB Uniform Guidance (2 CFR 200.430). Please access and review the OMB home page and information provided.
Concise and highly detailed definitions are included in OMB Circular A-21. The information is updated on a regular basis. The federal government requires a system of record-keeping regarding effort.
- Effort Reporting is required by OMB Uniform Guidance 2 CFR 200.430
- Effort Reporting was originally established in OMB Circular A-21, Cost Principles for Educational Institutions (1979)
Non-professional employees must certify effort monthly, and professional employees generally certify on a semester basis. Effort certification is required for the following WSU employees:
- Those whose earnings are charged directly (at least in part) to federal and nonfederal sponsored projects (Workday funds FD043, FD044, FD048, and FD085), including departmental research administrators whose salary has been approved as a direct charge to sponsored projects.
- Those whose earnings include federal appropriation monies (Workday funds FD035-FD042).
- Those who contribute effort for cost sharing purposes, whose salaries are not charged to any of the funds listed above.
NOTE: when completing the effort report, any change in workload exceeding 5% (increase or decrease) is considered significant and requires a corresponding change to the accounting records.
It is important that the effort reported not conflict with other institutional or college reports that require the distribution of an individual’s time especially when an individual is paid 100% from a grant. Auditors have been very aggressive in pursuing other institutional reports for activity of faculty members in order to substantiate the percentages of effort reported on federally sponsored agreements. Conflict can occur when distributing effort contributed to major functions such as instruction and organized research, cost sharing, departmental administration, and sponsored agreements, since documentation is available in the college which reflects teaching assignments and administrative duties, and would be available for audit review.
Effort is the time spent conducting University business/activities. It is expressed as a percentage of the individual’s total University effort and is not calculated on a 40-hour work week. For example, for someone who is employed by WSU for only 10 hours, the 10 hours represents 100% effort.
Example: Your usual work week is 60 hours during the reporting period. Your project’s activities total 20hours.
(20 hrs of Project Activity) / (60 hrs of Total University Activity) X 100 = 33.33% Project Effort
Effort Reporting is a way to verify that effort required as a condition of an award has actually been completed and is required by the federal government. An effort report is needed for any employee whose salary or any portion of salary, including cost sharing commitment is charged to a sponsored project.
Effort Certification is a process through which the certifier (PI/FACULTY) attests that the compensation charged to a federally sponsored award, including federal flow-through funds was a reasonable reflection of effort spent. Significant variances between payroll charged and actual effort devoted must be corrected (via PAA) BEFORE effort is certified.
**Spring 2021 period (12/16/2020-5/15/2021)
Spring Period (01/01-05/15)
Summer Period (05/16-08/15)
Fall (08/16-12/31)
**Due to the Workday implementation, only the Spring 2021 period is December 16, 2020
Efforts MUST be certified within 60 days after the effort certification process is initiated as late certification is a compliance issue that could lead to loss of funding. Effort remaining uncertified 60 days after the effort certification process is initiated for any period may be subject to administrative review and result SPS inactivating the relevant grant worktag(s) to preclude further expenses from being charged to the affected projects until all effort is certified.
A new effort period is initiated each term on the 20th of the month after final examinations, with a certification deadline set for the 20th of the following month.” For example, Spring 2024 examinations end on May 3rd, therefore, a new effort period will be initiated on May 20th with a deadline of June 20th.
Section 7.5 of the NIH Grants Policy Statement would allow it under rare circumstances with justifiable reasons (“to correct an error”
or “to transfer to correct project” are not sufficient).
- Re-certification should only occur in rare and justifiable situations. Administrative oversight(error) is not allowed.
- May be indicative of poor internal controls.
- Prevailing circumstances for the recertification may make the recertification unallowable (e.g., debit award has unexpended balance, PAA close to end date of award, PAA initiator did not confer with PI or effort certifier).
Effort can be re-certified within the effort certification period, but one should provide the reasons for the re-certification. Past the 60days deadline, if re-certification is needed, a signed document by the PI, Department Head and Certified Approver with an explanation of the re-certification will be needed.
The signed document should include:
- Effort period
- A detailed description of the activities performed that benefited the sponsored project.
- Steps you are taking to prevent this to happen next time
Per our cost transfer policy and federal guidelines, grant to grant transfers > 90 days from the transaction are unallowable—especially when the reason is administrative oversight.
Cost share represents the portion of the total project costs paid by the University or a third party, rather than the sponsor.
Failure to Meet Cost Sharing Commitments
The University may be held liable if it fails to meet commitments for mandatory and/or voluntary committed cost share. Failure to meet the cost share commitments may result in a reduction of sponsor funding and thus require the department or college to fund the amount of the reduction.
Cost share is required when clearly stated by the sponsor as a condition of the award (mandatory cost share). Cost share requirements are generally set forth in the NOFO, program announcement (PA), or request for proposal (RFP). (See BPPM 40.02.)If a concern exists regarding cost sharing an employee, review this information:
Reporting cost share that includes a University employee’s salary and benefits is accomplished when creating that employee’s payroll costing allocation. See the Workday Assign Costing Allocation reference guide.
Any administration/clerical position not meeting the below criteria is generally ineligible to be direct charged or cost shared to a sponsored agreement:
- The agency-approved budget specifically includes Departmental Administration and/or Clerical personnel
- There is a specific reference to matching with Departmental Administration/Clerical personnel in the award
For further information regarding effort certification procedures and requirements, see the resources below:
The following resources may also be helpful:
- BPPM 40.37 – Effort Certification
- BPPM 40.40 – Institutional Base Salary & Salary Cap
- BPPM 40.33: Cost Share and Match
- Effort Reference Guide
- Cost Share Reference Guide
- Payroll Accounting Adjustment Reference Guide
- Workday Grants reference guides
External
2 CFR 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, including but not limited to:
- 2 CFR 200.430 Compensation – Personal Services
- 2 CFR 200.431 Compensation – Fringe Benefits
- OMB Uniform Guidance § 200.00
- UW Cost Share Training
- University Of Nevada Effort Training
Effort FAQ
“Effort” is your work on a project, whether the sponsor pays your salary or not
Effort Reporting is a way to verify that effort required as a condition of an award has actually been completed and is required by the federal government. An effort report is needed for any employee whose salary or any portion of salary, including cost sharing commitment is charged to a sponsored project.
When you write yourself into a grant proposal, you are committing your effort to the sponsor. A reduction of effort by 25% or more, paid or unpaid on federal grant, must have agency approval.
The Aggregate tab allows you to confirm more easily what was reported per Pay Period on the Effort Certification. It gives a one-page summary of the different pay periods instead of having to look at each separately. It also adds all payroll components (Regular, Sick, Leave, Holiday, etc.) together showing the total, so you do not need to add them like you do on the Details tab. This makes it easier for the user to compare it to payroll records when necessary.
No.
The time you spend on these activities cannot be charged:
- Writing a proposal;
- Serving on an institutional review board, institutional animal care and use committee, or other research committee;
- Serving on a departmental or university service committee.
PI, and Faculty members. PIs cannot certify for faculty members. If a Principal Investigator (PI), faculty members (or other employee) leaves the university, a person with first-hand knowledge of the performed activities, or other appointees that could verify activities performed, can certify the effort.
If you are seeing Effort Certifications routed to your ECR’s that you don’t think should be, it would be because the employee was paid on a grant worktag that belongs to your cost center.
In accordance with the BPPM 40.37 – Effort Certification , Efforts must be certified within thirty days of initiation of the effort certification process after each effort period.
Effort remaining uncertified 60 days after the effort certification process is initiated for any period may be subject to administrative review and result SPS inactivating the relevant grant worktag(s) to preclude further expenses from being charged to the affected projects until all effort is certified.
SPRING 2021 (12/16/2020-05/15/2021) | 6/20/2021 |
SUMMER 2021 (05/16/2021-08/15/2021) | 9/20/2021 |
FALL 2021 (08/16/2021-12/31/2021) | 1/20/2022 |
SPRING 2022 (01/01/2022-05/15/2022) | 6/26/2022 |
SUMMER 2022 (05/16/2022-08/15/2022) | 9/30/2022 |
FALL 2022 (08/16/2022-12/31/2022) | 2/24/2023 |
SPRING 2023 (01/01/2023-05/15/2023) | 8/10/2023 |
- Suspension or termination of awards
- Civil/criminal violations
- Audits issues
- Loss of future funding
Yes, within the effort certification period, but you should provide the reasons for the recertification. All certifications must be completed by the due date as late certification is a compliance issue that could lead to loss of funding.
- Should only occur in rare and justifiable situations. Administrative oversight(error) is not allowed.
- May be indicative of poor internal controls.
- Prevailing circumstances for the recertification may make the recertification unallowable (e.g., debit award has unexpended balance, PAA close to end date of award, PAA initiator did not confer with PI or effort certifier).
Please work with your managers for guidance when faced with approving a PAA. Some items to consider:
- Does it meet the standards in our BPPM 30.25: https://policies.wsu.edu/prf/index/manuals/30-00-contents/30-25-expenditure-transfers-funding-sources/
- If over 90 days from the date of the transaction, is there a valid reason to move the costs? Reasons such as “administrative oversight” are not acceptable reasons according to federal guidelines.
- Is there an effort certification for the PAA in question?
- Processing a PAA after effort is already certified is typically only allowable in very limited circumstances (e.g., removing charges from a sponsored award). If you are moving costs onto a sponsored project after someone has certified effort, then you are invalidating that certification. This undermines the integrity of our effort certification process.
Make sure there is a justification for the untimely PAA.
Effort is not based on the number of hours worked per week; it is based on the total time spent on sponsored university activities, regardless of hours worked.
Effort can be re-certified within the effort certification period, but one should provide the reasons for the re-certification. Past the 60days deadline, if re-certification is needed, a signed document by the PI, Department Head and Certified Approver with an explanation of the re-certification will be needed.
The signed document should include:
- Effort period
- A detailed description of the activities performed that benefited the sponsored project.
- Steps you are taking to prevent this from happening in the future
The Effort Certification business process is set up so that EC’s for terminated employees route to the grant’s Cost Center Manager for approval. If EC was generated before the employee’s status was changed to terminated, it will route based on their status at that time, so no re-routing automatically.
Efforts can be approved / certified by someone with verifiable means such as employee’s supervisor, PI, someone with knowledge about the employee’s work or has written documents to back up the effort.
Note that EFFORT Certs are routed first to the employee’s sup org’s Effort Certification Reviewer (Supervisory). This allows Effort Certs to then be routed to other Effort Cert Reviewer (Cost Center) if the employee is paid on grants located in different cost centers. Please note it will go to all the ECR’s assigned for their sup org.
You could run CR GRA Award and Grant Roles and filter the Cost Center column for your cost centers. All grant managers assigned will be listed in the Grant Manager column.
A report that could be used to predict what the effort could look like. Create Pro Forma Effort Certification Instructions found here.
You can use your Effort Cert Work Area – Overview. Click on the link at the bottom right
and sort the awaiting person column by the person’s name to see all awaiting them.
The word “no” after the “I Certify” language is just saying that at that moment, there has been no approval for the certification entered into the system yet. Once they have certified the Effort Certification, it will change to say “yes” after the “I Certify” language.
MOD Team is working on fixing the issue.
You can find the status of an effort (including awaiting persons) by using the Effort Certification Status Report in workday
Workday is still not handling retroactive pay as wanted. Send SPS a signed memo explaining what happened to add to the EC after it is approved. As of right now, memos can only be added to approved ECs.
Notes: Certifying effort is not the same as certifying payroll. Certification must reasonably reflect all the effort for all the activities that are covered by your university compensation.
When SPS (Sponsored Programs Services) cancels an Effort Certification for a PAA to be completed, that particular business process ends at that point. Then SPS kicks off another round of Effort Certifications for everyone whose Effort Certification was cancelled each Wednesday. Basically when an effort is cancelled, a new one is generated the Wednesday following it being cancelled.
We would like to advise the grants manager that moving forward the PAAs need to be processed to align with the effort cycle and we will make an exception now as we enhance campus awareness of best practices with the effort reporting process.