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Effort Reporting Process

How do I recertify the FEC?

As of March 2017, recertifications are processed electronically.  Follow the instructions on MAA website.  Note, the ASTRA role “View and Update Effort Report” is needed to process a recertification online.

What should I do if my FEC does not reasonably reflect my effort?

First, do not certify the FEC. Make sure all corrections have been made before doing so as eFECS will automatically update the FEC information to incorporate changes processed if it has not been certified thus avoiding the need to recertify. If you do certify your FEC and a correction is subsequently made you will need to recertify it.

Second, contact your FEC coordinator to inform him/her there is a problem with what is reflected on the FEC as it does not reasonably reflect your actual effort. This most commonly results from incorrect salary distributions or an issue related to cost sharing. In these cases a retroactive salary distribution correction and/or cost share adjustment can be made.

While it sometimes can take time to get changes processed and result in the FEC certification being delinquent, it is the better option than to knowingly certify to something incorrect.

When does an FEC need to be recertified?

An FEC most commonly will need to be recertified in the eFECS system when there is a retroactive change in salary distributions and/or cost share commitments/effort that has a material impact on the percentages previously certified to for sponsored budgets, i.e., the adjustment changes the percentages.  If there are no (or minimal) changes impacting sponsored budgets, a recertification is not necessary.

While we strive to avoid the recertification of FECs as they are frequently reviewed and questioned by auditors, it is critically important that when an error is detected, the FEC be corrected even if it requires it to be recertified.  One common cause of this is late receipt of awards from sponsors.

It is recommended that, in these cases, an advance budget be requested, especially if the anticipated receipt of the award is past the complete by date for the FEC.  Also, while the late certification of an FEC is non-compliant with UW policies, it is a lesser issue than knowingly certifying an incorrect FEC.

Reduced Responsibilities

A faculty member is on “reduced responsibility” after one of his/her grants has ended. However, this faculty member still has a 100% appointment. What is he/she allowed (and not allowed) to do in this newfound time?

A faculty member’s appointment is not impacted as a result of being placed on Reduced Responsibility (RR). Rather, it impacts his/her compensated FTE (e.g. salary reduction with proportionate reduction in responsibilities). When a faculty member’s salary has been reduced based on RR status, it is recognized that his or her University responsibilities will be reduced accordingly, giving the faculty member the opportunity to engage, if desired, in uncompensated activities that are outside his or her RR status such as scholarly activity including proposal preparation.

 

For example, a 1.0 FTE faculty member loses 25% funding and moves into a 75% RR status (65% of the non-RR status is funded from other grant sources; 10% is funded from non-sponsored UW sources for scholarly activities). The remaining 25% unfunded time may be used as uncompensated time on additional scholarly activities while in RR status of 75%.  It is important to note however, that the faculty member’s unit must provide funding for scholarly activity, e.g. proposal preparation, as described in GIM 38 - Funding Support for Institutional Scholarly Activities.

GCCR

Why does the GCCR system create a second GCCR for the same period when the PI changes?

The Grant and Contract Certification Report (GCCR) is required to be maintained in the home department of the Principal Investigator. Therefore, to determine compliance with the GCCR process, MAA relies on the departmental downloads, i.e. if the GCCR has not been downloaded, it has not been certified. Downloading the GCCR removes the report from the overdue list.

Note, when there is a change in PI, the system will create a GCCR for the new PI. This may result in a duplication of a report for a period already certified by the original PI. In this case there is not need for the new PI to certify again. However downloading the GCCR will remove it from the overdue report.

Can the signature on the GCCR be scanned/faxed?

No, the certification must be an original ink signature.

Since I certify effort on the GCCR, why do I also have to sign the BARS?

The Grant and Contract Certification (GCCR) process is an alternative approach to the Faculty effort Certification (FEC) process which the federal government approved for certifying non-faculty effort. This certification, both faculty and non faculty, is a federal requirement. The BARS do not include the appropriate certification statement and were not part of the original agreement with the federal government. To certify on the BARS would depart from the federally approved use of the GCCR to certify effort for non faculty.

The PI's name is spelled incorrectly on the GCCR. Where do I go to fix this?

The GCCR pulls the PIs name from the FAS Budget Index. Check to see if it is spelled incorrectly there. If it's incorrect contact GCA via Grant Tracker.

I received an email that said GCCRs were ready to download, but when I went to download the reports I got the following message “There are no results that match the parameters you have input.”

This is a blanket email that will go out to all WUC codes. If there is no appropriate activity on the budget, it will not appear on your report. For instance, if the only activity is faculty effort, the budget will not appear on the GCCR. The faculty will certify this effort on the FEC.

There is a budget on my GCCR report that is not mine. How can I fix this?

To change an incorrect WUC, contact the Payroll Office at ischelp@uw.edu. Follow the same procedure for PIs who are missing from your GCCRs.

Why is one of my PIs not showing in the "Principal Investigator" drop down list after selecting my WUC?

It is most likely because there are no budgets currently assigned to the missing PI. Verify that the budget for which the PI is responsible for certifying has the correct PI EID and PI name in MyFinancial Desktop, Budget Profile.

eFECS System

Why do faculty who are not paid or compensated at 100% display as 100% on the FEC?

The federal government requires that effort reports reflect 100% of the faculty members' compensated effort. The change to the FEC to reflect 100% alleviates auditing challenges with federal regulations. Faculty whose Average Paid FTE during a reporting cycle does not equal a 1.0 equivalent Workday salary rate will fall into the above scenario. The averaged IBS value ($) associated with the Average Paid FTE, is then represented as 100% of the faculty member's IBS for the FEC cycle.

Will there be access to an FEC mid cycle?

No, FEC's become available for online viewing after payroll transactions for the final pay period in the FEC cycle have posted or approximately 23 days after the end of the cycle. For mid-cycle reporting of cost sharing, use the Interim Cost Share Report process.

When using the Faculty Search box, what is meant by the error message No match found for xxxxx. The search criterion entered does not match the name, EID, or UW NetID of any faculty required to certify for a reporting period currently recognized by this s

The eFECS system will not return a name for individuals who are not required to certify. For example, if the individual does not have a qualifying faculty job code, is not paid on a sponsored project and/or does not have a formal cost share commitment set up in the Cost Share Module, they will not have an FEC and the search box will return the error message above. Separated faculty will continue to appear on the MyFaculty List, but will not appear in the Search box.

Why do some budgets display in the Online FEC view with a value of zero?

This most commonly occurs when there is original pay and a salary transfer on the same budget. Expanding the budget detail will reveal both the positive and the negative salary transactions.

Why would a faculty member who qualifies for an FEC not receive any notifications from eFECS?

Notifications are dependent upon the email address that is listed in Workday. If there is no email address listed, eFECS substitutes the faculty member's UWNet ID @ uw.edu and sends notifications to that email address. Login to myuw.washington.edu to ensure forwarding has been selected if the faculty member's email address is anything other than his/her UWNet ID @ uw.edu.

Can anyone see budget details on all budgets a faculty is paid on? (Even when a budget is not in their department?)

Yes click the "+" next to any budget number on the online FEC to view detailed salary information by pay period along with the IBS eligible earn type.

How will an online salary expense transfer (OSET) which transfers salary into a budget that was not reflected on the original FEC be displayed?

If the OSET is completed before the faculty member certifies the FEC, eFECS will reflect the salary transfer on the online FEC, normally one business day after it posts in the financial system. If the FEC has been certified any post-certification salary transfer, including a transfer that adds a new budget line, will be reflected on the View FEC with post-certification changes for recertification analysis screen (accessible through the link at the bottom left of the FEC).

Do changes, such as salary transfers, completed after certification appear on the FEC?

Once an FEC is certified, no changes can be made to the original report. There is, however, a Post Certification view that assists departments in recertifying. This view will display changes that occurred after the FEC was certified. Click on the link “View FEC with post certification changes” for recertification analysis located at the bottom of the FEC.

How is a recertified FEC reflected in eFECS?

Once the department completes the online recertification, the new recertified FEC is now the official FEC. Status of this FEC will show "Recertified". FEC coordinators can still navigate to the originally certified FEC by following the link in the bottom left.

How will the system handle a grant that is only active for part of a cycle?

If an award is only active for part of the FEC period being reported, the system will prorate the effort. For example: The FEC reporting cycle is 1/1/XX-6/30/XX. The award period ends 2/28/XX and the faculty member provided 20% effort on the award from 1/1/XX - 2/28/XX. The FEC will spread the 20% over the entire FEC cycle thus reducing the effort percent for the quarter to 6.7%.

When a faculty member has separated from the University, who can certify their FEC?

There is provision for the Chair, Dean, Director or Division Head to certify on a faculty member’s behalf.  To do this the department Astra authorizer must assign the ASTRA role “Certify Others” to the Chair, Dean, Director or Division Head.  Once this is done they can now enter the name of the faculty they are certifying for in the Search box.

These individuals must have suitable means to confirm the work was completed such as direct supervision or an email from the separated faculty confirming the accuracy of the FEC.

Can MAA authorize a chair to certify the FEC for another faculty and/or add or remove authorizations for FEC Coordinators?

No.  All roles in eFECS are set up and removed by the department's ASTRA authorizer.

Which browsers can I use to operate the eFECS Effort Reporting application?

Mozilla Firefox, Internet Explorer and Google Chrome are all supported browsers. This product is standards-compliant and may work with other browsers.

Service and Recharge Centers

W9 Forms

On occassion a center may be asked by an external customer to complete a W9 form before a payment can be received.  For more information on how to fill out a W9 visit the following link. 

https://f2.washington.edu/fm/tax

Can I purchase food on my center budget?

Food purchases are unallowable on recharge and cost center operating budgets* unless the following exceptions apply:

 

  • The center has a programmatic requirement for food purchases.  In other words the food being purchased must be essential to the operations of the center.  If this is the case, it should be clearly stated in your rate proposal.
  • Centers may purchase meals or refreshments for meetings or conferences IF technical information pertaining to the center’s operations is disseminated.  In such cases an agenda and other documentation must be kept on file to prove the content of the meeting/conference.  If the meeting/conference was not approved ahead of time in your proposal, a food approval form will be required.

Visit the following link for the food approval form, details on how to fill it out, and additional information on food purchases. http://f2.washington.edu/fm/food-approval

 

*Food purchases are allowable on reserve budgets (program type 21 & 23) if the purchase directly benefits the center, however centers must still comply with UW food approval policies.

Tech Recharge Fee on Recharge and Cost Centers

Current University guidelines allow for the Technology Recharge Fee to be included on approved recharge and cost center budgets, see http://www.washington.edu/uwit/trf.faq.html.  The percentage of the Tech Recharge Fee to the center should not exceed the FTE percentage of the associated employee assigned to the center.  For example, if an employee is assigned 50% to the recharge/cost center, the percentage of the Tech Recharge Fee charged to the recharge/cost center should not exceed 50% of the total amount assessed to the department.

 

 The two most appropriate allocation methodologies are:

  • Allocate the fee to individual rates based on the same allocation of the related salary
  • Allocate the fee to internal center overhead.

Centers should choose the methodology that most accurately reflects how costs reflect.

What is the difference between encumbrances and accrued expenses?

Encumbrances are not the same as accrued expenses.  Encumbrances can represent a number of things, but are most commonly used to represent an outstanding obligation or commitment.  These figures can be used for planning and or budgeting purposes, but they do not represent actual expenditures. 

 

For example, when a service contract is agreed upon procurement services will set up a purchase order in the system, the total dollar amount of the service contract will then show up as an encumbrance even though no services has been provided or paid for yet.  As services are received and payments made, the encumbrance is reduced. Encumbrance amounts also represent the open balance amounts of an order.  For more information please visit the encumbrance website, http://f2.washington.edu/fm/gca/encumbrances-0.

 

An accrued expense occurs when an item or service has been received within a certain period, but the payment for it did not post or was not recognized in that same period.

 

Encumbrance figures should not be included in the financial reports unless it is known that the encumbrance amount meets the accrued expense definition.

Am I stuck with my rates for a full year once they have been approved?

No.  Centers are allowed to submit mid year rate adjustments at any point throughout a center's rate cycle.

How do I go about invoicing external customers?

Please refer to the following website for information on invoice receivables, https://f2.washington.edu/fm/sfs/ir/intro .  Included on the site is a link to a document that explains in detail the receivables procedures including guidlines and standards for the State of Washington.

What is the difference between a recharge center and a cost center?

The main difference between the two is the size of the center.  A recharge center is defined as generating $1 million or more in total revenue and/or charging $175K or more to UW federally funded budgets within a fiscal year.  A cost center is defined as generating less than $1 million in revenue AND charging less than $175K to UW federally funded budgets within a fiscal year.  Recharge centers are required to send their annual rate proposals and financial reports to MAA as well as their Dean's/VP's Office, whereas cost centers are only required to send their annual rate proposals and financial reports to their Dean's/VP's Office.  All other policies and guidelines apply to both budget types.

Does the NIH salary cap apply to recharge and cost centers?

No.  The NIH salary cap does not apply to recharge and cost centers.

When do cost centers need to submit their rates to MAA for review and approval?

Cost centers must submit their rate proposals to MAA for review and approval when any of the following apply:

  1. The initial establishment of the center,
  2. New services or products are added,
  3. Significant changes are made to the methodology used to calculate the rate(s).
How Are Overtime Charges Treated on Recharge and Cost Centers?

Overtime charges are generally allowable for personnel other than faculty members and should be distributed proportionately to all activities during the time period in which they are earned.   

e.g. Employee A, who is overtime eligible, works 20 hours on cost Center 14-XXXX  and 30 hours on budget XX-XXXX for a total of 50 hours.  Cost Center 14-XXXX should be charge 40% (20/50) of both the regular earnings and the overtime earning for employee A. In addition, if employee A’s cost center activity involved more than one job for the time period, each job would normally share in the overtime earnings charged to the cost center.

Overtime charges can be recovered in two ways.  1) If overtime can be estimated with a high degree of certainty the incremental costs should be distributed to and included in the appropriate services prior to determining the rates for those services.  2) If overtime cannot be estimated with a high degree of certainty or is unanticipated the cost can be recovered through the next proposal cycle, via the over/under recovery adjustment.  3) The incremental cost of the overtime (overtime salaries plus the additional fringe benefits) can be added to the charges for ALL services (jobs) that employee worked on during the period of time the overtime was earned. Note, this is not a rate adjustment rather it represents only the actual incremental (additional) costs of the overtime.

What is the Uniform Guidance?

Uniform Guidance is short for "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards".  This is a set of federal guidelines laid out by the Office of Management and Budget (OMB) that recharge and cost centers must adhere to, with some exceptions.  For additional information or to browse the Uniform Guidance click here.

Imputing Revenues for Recharge and Cost Centers

Imputing Revenue for Recharge and Cost Centers – Imputing revenue represents the process of adjusting revenue to reflect an amount free from subsidies and other less than full reimbursements, e.g., bad debts, when determining future rates for recharging.  In essence it adjusts revenue to assume full reimbursement from all users of the recharge/cost center.  This is necessary to ensure the Federal government does not wholly or partially participate in the subsidies or other less than full reimbursements.  Recovery of the subsidy would need to be done through non Federal sources and usually from non University sources.  Most commonly this would be recovered from external users by crediting the center’s reserve budget or an alternate budget.  Depending on the amount of the subsidy this could also be recovered over a period of time, e.g., 2-3 years.

 

Example:

Department contributes a $10,000 piece of equipment to a recharge center. In consideration of this the recharge center provides the department with $10,000 of unbilled service.  For the current rate cycle the annual operating costs for the center were estimated to be $100,000.  For determining rates for the next rate setting cycle the unit would need to determine their carry forward balance as follows:

Actual expenses for the year                      $101,000

Less:

Actual revenue (internal/external)                (89,000)

Imputed revenue1                                             (10,000)

 

Net (profit)/loss (carry forward)               $    2,000

 

1 Represents unbilled services to department in consideration of equipment purchase of $10,000

How do I handle mid-year equipment purchases?

Mid-year equipment purchases represent equipment acquisitions that do not coincide with the fiscal period of the recharge/cost center.   As a result, they are sometimes included in the annual rate proposal if anticipated or are not included if they were not anticipated or not able to accurately estimate.  In either situation, the following applies:

Depreciation for mid-year equipment purchases cannot be included in quarterly JVs until the equipment has been placed into service in the center and a new depreciation schedule has been approved by the Dean/VP’s office and MAA.

Special consideration should be given when any portion of the acquisition will be charged to a sponsored project(s) or the equipment will not be used 100% by the center. These situations should be discussed with your Dean/VP’s office and MAA as soon as possible to determine if there are any unique issues associated with the equipment (e.g., program income implications).

 

Including Mid-Year Equipment Purchases in annual proposal

When the purchase of a piece of equipment for the operation of a recharge/cost center (center) is expected to occur within a period covered by a rate schedule, that piece of equipment may be included in the depreciation schedule of the rate proposal.

For a future equipment purchase to be eligible for inclusion in a center rate proposal, the acquisition date and cost of the equipment should be known or accurately estimated.

The depreciation start date should be based on the anticipated acquisition date. This is usually the start of the quarter following the acquisition date of the equipment. Center rates cannot include depreciation for equipment for any period prior to the anticipated acquisition date. For example, if the center rate begins July 1st and the anticipated in service placement of the new equipment is October 1st, the center can only include 3 quarters, or 75%, of the annual depreciation for that year.

 

Mid-Year Equipment Purchases not included in annual proposal

When the purchase of a piece of equipment for the operation of a center occurs within a period covered by a rate schedule and that piece of equipment was not included on the depreciation schedule in the rate proposal, centers should update their depreciation schedule and determine whether a mid-year rate adjustment is needed. 

  • If a mid-year rate adjustment is necessary,  the center should submit an adjustment approval request to both their Dean/VP’s office and/or MAA highlighting the updated costs and the new depreciation schedule.
  • If a mid-year rate adjustment is not necessary, the center should submit the new depreciation schedule to their Dean/VP’s office and/or MAA notating that a new proposal is not necessary. 
Quarterly Report Escalation

Beginning with Quarter 3 2014 MAA will begin to send delinquent letters to the Recharge Centers contact and cc the corresponding Dean/VP Office. The letters will be sent 8 weeks after the quarter ends to give centers time to finalize the report. 

 

This letter will only be sent to Recharge Centers as Cost Centers are not required to send quarterly reports only to their Dean’s/VP’s office.

 

Summer (7/1-9/30)–

                Due date second week of November

                Escalation letter sent first week of December

 

Autumn (10/1-12/31) –

                Due date second week of February

                Escalation letter sent first week of March

 

Winter (12/1-3/31) –

                Due date second week of May

                Escalation letter sent first week of June

 

Spring (4/1-6/30) –

                Due date second week of September (due to fiscal year end)

                Escalation letter sent last week of September

Rate Proposal Escalation

Recharge and Cost Centers are responsible for submitting rate proposals in a timely manner. Beginning March 2014 MAA will begin sending courtesy emails to the Recharge Center contacts reminding them of the need to submit a new rate proposal. This email will be sent approximately 6 weeks prior to the expiration of the current rates.

 

Should the proposal not be received by MAA prior to the expiration of the current rates, a second follow-up email will be sent to the Dean/VP office with a copy to the Recharge Center contact. MAA will maintain a list of delinquent centers which will be provided to the Internal Audit Office on a monthly basis.

 

These emails will only be sent to Recharge Centers as the responsibility for conducting annual rate reviews for Cost Centers is the responsibility of the Deans/VPs office.

Capital Lease Policy - Recording Payments

Capital leases essentially represent capital acquisitions and therefore must be handled in a like manner.  Additionally, capital lease payments may not provide an accurate representation of the center’s depreciation for the asset(s).   For this reason recharge and cost centers’ capital lease principle payments must be charged to the center’s reserve account (budget) and not to the center’s operating account (budget).  To recover the cost of the asset(s) the center must determine the appropriate annual center depreciation which may be charged to the center’s operating account and recovered through their recharge rates.  Note, external interest associated with capital leases should be charged to centers’ operating accounts and recovered through the recharge rates.

 

Recharge/cost centers who are presently charging capital leases to their operating account may be grandfathered on this change on a case-by-case basis but only for current capital leases.  Future capital leases for these centers must be handled in the above manner.  If your center is one that presently has this arrangement in place please contact Management Accounting and Analysis so that we may assess your specific situation and advise you of actions to be taken. 

Recharge Center Variance Analysis

In an effort to ensure centers are costing their rates appropriately a variance analysis report reflecting the previous year’s estimated costs to actual costs must be submitted within 45 days after the close of the rate cycle. The report should include an explanation of any material differences, i.e., +\- 10% or more AND +/- $5,000 or more, from the original cost estimate.  If there are any material encumbrances they should also be reflected.

For example, if the estimate for salaries was $30,000 and the variance +$3,500 an explanation would NOT be required as the variance is less than $5,000 even though it is greater than 10%.  Similarly, if the salary estimate was $75,000 and the variance +$5,500, an explanation would NOT be required because the variance is less than 10%.  Only if the variance dollar amount is equal to or greater than $5,000 AND the variance percentage is equal to or greater than 10% will an explanation be required.

A variance report excel template can be found on the MAA website under Forms/Templates.

Budget Actual Diff % Material Reason

10,000

7,500

2,500

25.0%

No

<5000

10,000

2,500

7,500

75.0%

Yes

>5000 & >10%

25,000

21,000

4,000

16.0%

No

<5000

25,000

19,000

6,000

24.0%

Yes

>5000 & >10%

50,000

54,000

(4,000)

-8.0%

No

>5000 & >10%

50,000

43,000

7,000

14.0%

Yes

>5000 & >10%

75,000

69,000

6,000

8.0%

No

<10%

75,000

81,000

(6,000)

-8.0%

Yes

<10%

100,000

91,000

9,000

9.0%

Yes

<10%

100,000

89,000

11,000

11.0%

Yes

>5000 & >10%

Salary Cap and K Awards

How is the salary cap cost sharing associated with non DHHS grants determined?

If the non DHHS sponsor applies the DHHS salary cap then eFECS utilizes the same process above.  However, if the non DHHS sponsor charges a unique salary cap amount, i.e., has a different threshold, eFECS does not calculate the amount of the salary cap cost sharing but does place an indicator next to the impacted budget on the FEC to alert the department that they need to make the calculation and manually adjust the salary cap cost sharing prior to the FEC being certified.

Can salary cap cost sharing be used to satisfy the 75% requirement of a K Award?

Cap cost sharing can contribute toward fulfilling the direct charged effort commitment on a K Award.  The sum of the direct charged salary, salary cap cost sharing and K Award cost share should equal the 75% commitment of effort.

What are the rules regarding salary supplementation for K Awards?

Salary charged to a K Award may not be sufficient to fund the 9 person months effort required by the K Award. Supplementation provides funding for that portion of the 75% effort requirement not paid for by the award. The University may 'supplement' the K Award salary with other institutional funds however, supplementation may not be from other federal funds unless specifically authorized by the federal program from which such funds are derived. In no case may additional PHS funds beyond those provided in the K award be used for salary supplementation. The PI may be paid on other federal awards for the remaining 25% effort.

Can Federal support be used for salary above the K effort?

The question of whether or not Federal support can be used for salary above the K award effort may actually depend on the particular K award. Some K awards actually require other NIH support. Others imply that since the K award experience is considered full-time there is no room for Federal funded activities outside of the K award activities. However, in most cases, if only 75% effort is devoted to the K award, the remaining 25% can be devoted to other projects as long as they are K related and contribute to the K award experience.

How is the salary cap cost sharing associated with Department of Health and Human Services (DHHS) grants determined?

The eFECS system utilizes budget profile attributes associated with each budget to determine what FECs and budgets on each FEC are subject to the DHHS salary cap.  Once determined, the salary cap cost sharing is then calculated using a combination of the salary dollars and percent distribution directly charged to the budget subject to the salary cap and the effective salary cap threshold.  It is critical to note that this calculation is based on the assumption the department has adjusted the directly charged salary to the capped amount.

Part-Time Faculty

How do part-time faculty on 'soft' money fund non-sponsored activities?

proposal preparation effort must come from non-sponsored funds. Just like full-time faculty, part-time faculty (those with an appointment of less than 1.0) may not volunteer their time for proposal writing or other non-sponsored activities.  Note, part-time is NOT the same as reduced responsibilities (See GIM 38 – Faculty Reduced Responsibility Status Involving External Funding)

Effort Policy Questions

What are faculty effort certification reports (FECs) and who must complete them?

It is a federal requirement that all salaries charged either directly to a federally funded sponsored agreement and/or to non-sponsored sources for the fulfillment of a cost-share commitment being met via faculty effort not charged directly to the sponsored agreement, be supported by records that provide assurance that the charges reasonably reflect the work performed.  The UW meets these requirements via the faculty effort certification reports (FECs).

FECs are semi-annual reports designed to meet the federal requirements described above.  Thus, a faculty member will receive, and must complete, an FEC if he or she is paid by the University of Washington and

  • Performs effort paid on federal and/or nonfederal sponsored projects; and/or
  • Performs cost-sharing on federal and/or nonfederal sponsored projects.
Who needs to certify faculty effort?

While technically a federal requirement, the UW presently requires this certification for all sponsored agreements regardless of funding source.

Why do faculty need to certify their effort on various activities?

The federal government requires that charges to federal awards for salaries and wages be based on records that represent a reasonable approximation of the work performed on those federal awards relative to the total activity for which the University compensates the faculty member. As part of meeting this requirement, faculty review and certify their effort.

What implications arise from inaccurate certification of faculty effort?

Charging and certifying salaries that are not properly supported could lead to audit findings, disallowances, fines, suspension and debarment, as well as other sanctions at the institutional and/or individual level.

What types of activities are faculty required to track and certify?

The purpose of the FEC is to certify that the compensation (institutional base salary) charged to each sponsored agreement is reasonable in relation to all other compensated UW activities. Thus, faculty completing FECs must take into consideration research, instruction, administration, service and clinical activity (excludes clinical incentive payments). See GIM 35.

What types of activities are included in one’s institutional salary?

Institutional base salary (IBS) is the annual compensation, including A/B salary as it relates to tenured faculty, paid by the University of Washington for an employee’s appointment, whether that individual’s time is spent on research, instruction, administration, service or clinical activity. IBS excludes any income that an individual is permitted to earn outside of duties for the University of Washington.

The components of IBS are base salary (regular salary, summer salary, paid professional leave and salary for retired faculty); administrative supplements (ADS); endowed supplements (ENS); and clinical salary (UW Physicians (UWP) and Children’s University Medical Group (CUMG)).  Note, clinical incentive salaries are excluded from IBS.

How do faculty calculate their time and effort on these various activities?

A faculty work week is composed of the average number of hours a faculty member normally works during a week. Hours are to be averaged over the effort reporting period. For many faculty members, this number will vary from one week to another; there is not a standard 40-hour work week for faculty.

 

Example: If, within a six-month cycle, a faculty member worked thirteen 60-hour weeks and thirteen 40-hour weeks, his/her average work week would be 50 hours. Hours are averaged over the six-month effort reporting cycle. 

 

Faculty are not required to keep track of hours on a daily or even weekly basis. They are, however, expected to estimate, as a percentage of their total compensated (IBS) effort, that what they do on an average per week, regardless of the actual number of hours worked, days of the week or hours of the day, over the reporting period is reasonably reflected on their FEC report. This allows them to certify in good faith that their effort compensated on a sponsored project is reasonable.

If federal grants cover 80% of a faculty member’s salary and other UW sources (e.g. gift, state funds) cover the other 20%, what activities can he/she engage in with that other 20% time?

This other 20% time is considered “non-sponsored” time. Salary support from non-sponsored funds may be used for activities such as teaching, administration, service, clinical activity, institutional governance and preparing new and competing renewal proposals. In addition, it may be used to fund cost shared effort commitments, i.e., effort devoted toward a sponsored project that is charged to other UW non-grant sources.

What counts as de minimis effort?

For effort certification purposes, University of Washington activities whose inclusion in or exclusion from total effort would not, in the aggregate, affect the percentages of effort allocated to sponsored activity, and therefore do not require separate tracking and funding.

Should faculty be paid on non-sponsored funds for time spent preparing new and competing grant proposals?

Yes. Time spent preparing new and competing renewal grant proposals represents an official University activity  normally covered under one’s institutional base salary using non-sponsored funding in an amount proportionate to one’s total FTE. Note, see the Reduced Responsibility FAQ section for exceptions.

Should faculty be paid on non-sponsored funds for time spent preparing non-competing proposals, supplements and extensions?

Unlike time spent preparing new and competing renewal grant proposals, the time spent on non-competing proposals, supplements and extensions involves reporting work on the existing grant period and therefore does not require non-sponsored funding.

Do the rules on salary allocation and funding non-sponsored activity including proposal preparation still apply to faculty who have secured grants from a non-federal sources?

The UW’s effort certification guidelines are based on federal Uniform Guidance, 2CFR 200.430. These regulations pertain to faculty whose salary is funded in any part with federal sponsored funds. The guidelines do not apply to faculty with salary supported only with non-federal sponsored funds.  Faculty should follow the non-federal sponsor’s policy, if any.

If the chair / director / unit head does not have the resources (or has allocated those resources to other competing priorities) to cover the costs of proposal preparation, what options are available to faculty members?

There are limited options when this occurs. One option is to identify an alternative funding source such as a gift budget to cover the cost. Also, in consultation with and concurrence from the unit head, if the faculty is involved in multiple scholarly (non-sponsored) activities, he/she could examine the possibility of rebalancing those efforts to allow time for proposal preparation or reducing time spent on some non-sponsored activities.

Another potential option is associated with Faculty Reduced Responsibility (RR) Status (GIM 38). This option, which includes the option to volunteer time for scholarly activity including proposal writing, is only available for faculty who have temporarily reduced their institutional responsibilities commensurate with a reduction in the amount of their institutional base salary (IBS) resulting from a loss in external funding. The faculty member must be on approved RR status to utilize this option.

F&A Rates and Costs

How are research cost recovery (RCR) funds distributed?

The UW has complex approaches to budgeting and resource allocations. For indirect funds, however, the Provost’s current distribution policy (see OPB FAQ #2. What revenue is distributed by ABB?) is to allocate 65% of the funds to centrally fund facilities, compliance and administrative functions and 35% to schools and colleges, who then decide how much flows to departments/units or individual faculty.

If a portion of RCR funds are returned to faculty, how can they be used?

If the faculty member’s college, school or department has a policy to return RCR funds to faculty, the funds may be used to further support faculty research and/or other scholarly activities, including costs associated with sponsored proposal preparation. Fund use is flexible provided they are used in accordance with University and/or State rules and school/department guidelines.

What does recovery for the indirect cost rate include?

Indirect cost reimbursement includes partial recovery of, among other things, the cost of proposal preparation, as well as activities such as building maintenance, the cost of utilities, security, hazardous waste disposal, telecommunications, libraries, cost of office supplies and copies for sponsored projects, departmental and college administrative support, purchasing, payroll, human resources, central sponsored program operations and compliance support offices and other infrastructure costs necessary for supporting sponsored awards.

Does the UW recover the full amount of indirect costs related to sponsored activity?

The UW does not recover all the indirect costs that support research and other sponsored activity for a number of reasons, including Federal government caps on administrative costs related to faculty administrative effort, including proposal preparation, and an overall cap on total institutional administrative costs within both academic units as well as central administrative units. Another significant impact on the recovery of indirect costs involves sponsors and certain sponsored agreements that do not reimburse at the full negotiated indirect cost rate. These sponsors and agreements fairly consistently result in an under-recovery of indirect costs of approximately 25%.

Cost Sharing

What constitutes a cost share commitment?

Cost-share commitments may arise when the proposal reflects a level of effort devoted to the sponsored project that is greater than the funding allocated for the commitment (e.g., 15% effort commitment but only 10% funding requested). They also may arise when the faculty member’s salary exceeds a sponsor’s limitation on the amount of salary that can be reimbursed, as in the case of salary  caps imposed by the National Institutes of Health

What does the message 'Cost Share commitments have been adjusted to reflect actual effort performed? View Details' mean?

This message indicates that cost share adjustments have been manually entered to reflect the actual effort performed. Click 'View Details' link, to review the cost share adjustments made. Before certification, cost share effort percentage may be adjusted using the 'Adjust/View Cost Share' button. If the 'Adjust/View' button is not available, contact the department's ASTRA authorizer to request the 'View and Update Effort Report' role.

Can the cost share actual effort percentages be modified online after the FEC is certified?

Changes can only be made to certified cost share by the faculty member recertifying the FEC. To accomplish, this contact GCA via Grant Tracker for requested changes to pledges. The faculty member should not recertify the FEC until the requested changes have been processed and appear in eFECS.  Contact efecs@uw.edu for recertification questions.

Can the PI rebudget charges on a budget that has a dollar match cost share from non-effort items to faculty salary?

Yes, with the following caveat. Regardless of whether the cost sharing is percent effort or dollars, if there is a specific commitment of effort by the PI or other key personnel, and the re-budgeting is caused by or results in a significant reduction (i.e. 25% or more) of that commitment, prior approval from the sponsor for this change needs to be obtained. Additionally, significant adjustments between effort and non-effort categories may imply a scope change. If this is the case, the sponsor must be contacted to approve the change.

When the cost share commitment is 10% why does it appear as 5% on the FEC? When the faculty member has a 9 month appointment, how can we document that the faculty actually performed 10% effort in the spring quarter?

Cost shared effort, as well as effort paid directly from the grant, is averaged over the FEC cycle for faculty reporting on both academic and calendar cycles. This may result in a percentage appearing on the FEC that is less than the committed amount.  For example, if the grant was only active for half of the cycle, a 10% percent commitment will appear as 5% on the FEC.  For faculty on an academic cycle, eFECS will identify if the commitment is for spring and upload the full 10% (the un-averaged percent) to the spring quarter in the Cost Share Module.

If a PI has a 20% direct charge commitment and a 5% cost share commitment, can he/she charge 15% to the grant and cost share 10%?

Yes, the relationship between the amount of effort charged directly to the grant and the amount cost shared is secondary to the PI meeting the combined (total) percent of his/her committed effort.

When there is a reduction in effort for an individual with both cost shared and directly charged salary, to which component does the reduction apply?

If the cost share is committed based on percent effort, and necessary approvals have been obtained (e.g., reduction of 25% or more) the reduction need not be prorated between the direct charged and cost shared effort commitment. It is critical however, that the total adjusted commitment be met which could be via direct salary charges only, cost share only or a combination of both. If the cost share is mandatory, i.e., dollar based, specific approval from the sponsor is required unless other sources of cost sharing are permissible and substituted.

Managing Faculty Effort

Is it sufficient for a faculty member to simply tell his/her Program Officer about a change of effort of 25% or more of current (committed) effort?

While it is important that the researcher maintains a good relationship with the Program Officer, communicating changes solely through the Program Officer is not sufficient.

Any decrease in effort of 25% or more by key personnel (as noted in the Notice of Grant Award) must be approved in writing prior to the change by the sponsors' Grants Officer.

An increase in effort greater than 25% for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored agreements.

Any change in the scope of work must also be approved in writing prior to the change by the sponsors' Grants Officer. All requests must be processed through the UW Office of Sponsored Programs in advance of the change.

Can a PI reduce his/her effort during an FEC cycle by 25% or more if the total effort during the budget period is compliant with the commitment on the grant? Does the PI still have to contact the sponsor for prior approval?

Normally it is acceptable for the effort commitment to be met over the project budget period and not tied to each FEC cycle. It is common for effort to vary from FEC cycle to FEC cycle provided the PI (or key personnel as designated in the Notice of Grant Award) does not (a) absence him/her self from the project for three consecutive months or more, or (b) reduce effort on the grant (direct and cost shared combined) by 25% or more over the budget period.

Does the original effort commitment extend to the no-cost extension period and, if yes, does the PI need to request permission to reduce his/her effort or does the institution have the authority to approve the reduction of effort when approving the no-cos

From a strict policy stand point, the terms and conditions of the award continue unless amended, so reducing effort by 25% or more would require sponsor approval.

The PI may, however, request that the sponsor approves eliminating or reducing the cost share during the no-cost extension process. While the University may approve the no-cost extension, the reduction of effort must be granted by the sponsor.

K awards present a unique case as they generally carry the requirement for a 75% commitment of total professional effort.

Can effort related to pursuing intellectual property be charged to sponsored agreements?

Consistent with the spirit of the Bayh-Dole Act, reasonable levels of activity related to pursuing intellectual property can be charged to grants.

These activities may include making an invention disclosure, meeting with UW’s tech transfer office (CoMotion) to discuss an invention disclosure, meeting with a patent attorney about a UW invention and/or reviewing internal actions on patent applications.

As with any effort charged to sponsored agreements, effort associated with the pursuit of intellectual property must be directly related to the sponsored project that is being charged. Where more than one award or activity contributed to the development of the intellectual property the effort distribution should be based on proportionate support provided under the awards or other equitable relationship.

The effort must also occur within the award period for it to be eligible for direct charging. These activities should be included within total University effort for effort reporting purposes.

If sub budgets are set up for a grant and salaries are redistributed between the parent and sub budget(s) after the faculty have certified their FECs, do they have to recertify their FECs?

Recertification of the FEC is only required if the level of effort on the sponsored project changes. Documenting the transfer of salaries to a sub budget number is not required as long as it does not change the overall project effort for the respective FEC cycle. This includes salary transfers from a parent budget to a sub budget or between sub budgets within the same project.

Summer Effort

Can a faculty member work on a grant proposal on their ‘own’ time during uncompensated summer months?

If a faculty member is clearly not being compensated (must be for entire pay periods) by the University then proposal preparation time would be considered volunteer time, i.e., performed on one’s own time. As such, no alternative (non-sponsored) funding needs to be obtained since no UW compensation is being received. However, if partial salary is being paid during the period in question this effort would be considered part of said compensation and a non-sponsored funding source needed.

How does summer salary relate to salary earned during the academic year?

The FEC process is conducted on a semi-annual schedule for faculty on 9 month appointments. Spring (3/16-6/15) and summer (6/16-9/15) effort is combined into a single FEC (March 16 - September 15). The rate of pay one can receive from a grant for work during the summer portion of this cycle is based on their 9 month academic year salary rate. While summer salary is considered part of institutional base salary, it is generally a unique line/designation in grant proposals.

For example, if the 9 month salary is $3,000 per month for a full-time appointment and there is a commitment of 50% effort for two months during the summer portion of the spring/summer cycle, the rate of pay for those two summer months would be $1,500 per month for 50% effort per month. On the FEC, the summer compensation will be added to the compensation received during the spring quarter for each sponsored budget and for 'Other Salary Sources'. The percent for each budget will then be calculated by dividing the total compensation charged to the budget divided by the total compensation received over the two quarters, i.e., FEC period.