Effort Reporting
The third major area focuses on reporting of effort spent by faculty and others in the performance of the sponsored project.
The PI is responsible for making determinations about the level of effort committed by himself/herself and others working on sponsored projects. Since the PI is responsible for the management of the project, s/he must be cognizant of the effort proposed and actually devoted by those working on the project. This responsibility is central to effective project management and it cannot be delegated to administrative staff.
Salary charged to a sponsored project must, at a minimum, be commensurate
with the effort committed. OMB
Circular A-21 (A-21A-21, OMB Circular
Cost Principles for Educational Institutions (05/10/2004) issued by the
U.S. Office of Management and Budget.) recognizes that precise allocation
of effort among various projects and activities is not always feasible and
therefore, in such cases, reasonable estimates are acceptable. It must be
remembered that research and instruction are inextricably linked which makes
it difficult to clearly separate them. This should not, however, be taken
to mean that guesswork can be employed; rather one must make good faith estimates
which are reasonable and based on effective oversight of the sponsored projects
and individual effort.
Salary charges are initially based on estimated levels of effort and must be modified when necessary to reflect actual circumstances. Again, this is a matter of effective management. One should not estimate a level of effort and then report that same estimate if the actual commitment of effort changes during the life of the project. It may be convenient to rely on the original estimates, but it is not good management practice and, in certifying the initial estimate without thoughtful review, one would be certifying false information. In the event of discovery, this carries with it serious negative consequences for the individual making the certification as well as for the institution as a whole.
Federal regulations require that reports be prepared no less frequently than every six months for all effort by faculty members and staff charged to sponsored projects and others activities. The certification report is sent to each academic department for review, amendment, and signature.
