Effective Date: December 1, 2006
Revised: August 1, 2016
This new policy below supersedes the December 2006 Effort Reporting Policy and the May 2009 Policy on Charging Compensation to Sponsored Projects for Officers of Instruction.
Federal regulations require charges to Federal awards for salaries and wages to be reasonable in relation to the work performed. Such charges must be documented in records that meet the standards of documentation set forth in the regulations, and must reflect a system of internal controls that ensure the charges are accurate, allowable, and properly allocated. Accordingly, it is University policy that:
- Compensation must be reasonable and conform to the University’s written policies, consistently applied.
- Compensation charges to sponsored projects may be made initially based upon the planned or estimated workload, provided that such estimates reasonably approximate the activity expected to be performed. The actual effort of each individual working on sponsored projects must be monitored, with charges modified as necessary based on variances between the estimated and actual effort.
- Significant changes in effort during the year, defined as material changes with a duration of greater than two months, should be reflected in the individual’s payroll distribution at the time the change occurs. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term.
- The required annual effort report is an after-the-fact review to assure that the final salary amounts charged to each sponsored project reasonably reflect the effort expended. The effort report must be signed by either the individual him/herself, or by a responsible official who has a reasonable basis, i.e., a suitable means of verification, for review of the activities of the individual(s). Comprehensive guidance on the annual certification process, including a description of best practices and institutional requirements for the certifier, can be found at www.effortreporting.columbia.edu.
- All necessary adjustments to compensation charged to sponsored projects must be made such that the final amount charged to the sponsored project reasonably reflects the effort expended and thus is accurate, allowable, and properly allocated.
The Effort Certification and Reporting Tool (“ECRT”) is used for monitoring effort throughout the year, and for documenting the annual effort review. Officers of the University who commit effort on sponsored projects, other than post docs and certain other roles, are required to review and sign their own effort reports. In addition, Principal Investigators are required to review and sign the effort reports of other individuals working on the Principal Investigator’s projects.
Special compensation issues, including summer salary, extra service pay, and other issues, are addressed at the end of the Policy.
To see the full text of this policy, please use the link on the right.