Compliance Team

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” 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.

• 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.