All faculty completing FECs, as well as staff involved in the FEC process, should carefully review FEC reports prior to certification.
- Confirm the FEC reasonably reflects effort devoted to the project.
- Verify compliance requirements of the sponsored projects being certified reflect sponsor terms and conditions.
Management Accounting and Analysis (MAA) conducts random reviews of certified effort reports. In some cases departments may be contacted to provide clarifying information. In some instances recertification of the FEC may be required.
The following list represents some, but not all, of the areas which MAA will conduct reviews.
- Effort commitments are met, both direct charged and cost shared. Sufficient funds are available to cover the cost share.
- The dollar amount of committed and actual effort is based on institutional base salary (IBS).
- Total committed effort (directly charged to sponsored agreements and cost shared) is met and documented when a shift in funding between grant and non-grant sources occurs.
- Committed cost shared effort is accounted for and certified.
- Required K-award effort is met, including any cost share requirements.
- Amounts exceeding the DHHS (NIH) salary cap are charged to non-federal funds.
- Online salary expense transfers (OSETs), especially those charging sponsored funds, are properly documented, i.e.., adequate justifications are provided. GIM 15, “Transfer of Expenditures Between Budgets,” details the necessary guidelines for these transfers,
- Changes that affect IBS are documented and accounted for (e.g.. overpayments and retro pay).
- The individual certifying the FEC on behalf of the faculty has adequate means to verify effort (Note, only deans, directors (of an organization or department level program), chairs and department chairs may certify on behalf of faculty).
- Certifications are done in a timely manner (UW provides approximately 60 days to complete after the end of each FEC cycle).
- Re-certifications are properly supported including why the report was originally certified and what circumstances changed to cause the re-certification.
In addition, auditors, both internal and external, focus attention on the following:
- Are 100% research funded faculty involved in activities that should be funded by sources other than grants.
- Are faculty with 5 or more federal awards over committed? Are the percentages of salary distributed to each of the projects reasonable?
- Are faculty seeking prior approval from the sponsor to change the level of effort proposed in their grant when required (typically when the change is 25% or more)?
- Are faculty with 1-2% of their effort on many awards contributing the effort promised?
- Are salary expense transfers (OSETs) infrequent, but timely when necessary? Of particular concern are those which impact a time period for which faculty have certified their effort.
- Is the University effort reporting policy being followed?