Effort Certification & Reporting Technology (ecrt)
Certification of effort associated with federal awards is required by Federal guidance (2 CFR §200.430). University faculty and staff are expected to charge or contribute their time to sponsored awards commensurate with the effort expended on sponsored activities.
The Certification Period begins on the 15th of November, February, May, and August and ends the 15th of the following month. Each quarter, there is a pre-review period in which the Department Effort Coordinator can review and manage accounts and awards associated to their department(s). The pre-review period is to ensure information in ecrt is accurate and up to date prior to certification.
FY Q1 (Jul 1 – Sep 30): begins October 16, ends November 14
FY Q2 (Oct 1 – Dec 31): begins January 16, ends February 14
FY Q3 (Jan 1 – Mar 31): begins April 15, ends May 14
FY Q4 (Apr 1 – Jun 30): begins July 16, ends August 14
Effort Reporting is a mechanism for confirming salary and wage charges to sponsored agreements are related to work performed and is expressed as a percent of total effort. CSU uses the Huron ecrt application for Project Statement Certification on a fiscal quarter basis.
For an expanded explanation, view the 5 KEY POINTS FOR TIME AND EFFORT REPORTING at CSU.
ecrt is an after-the-fact effort reporting system used by CSU to certify that salaries and wages charged or contributed to sponsored projects are reasonable and consistent with the portion of total institutional activity committed.
All project-personnel paid from or contributing time to (cost sharing) a sponsored project must report the amount of effort expended on sponsored activities.
Actual effort expended on each project must be reported and certified by a responsible person with suitable means of verification that the work was performed and that the salary charges are appropriate. Reported effort should be a reasonable estimate of how time was expended.
The portion of an individual’s effort devoted to institutional responsibilities like departmental administration, teaching, serving on committees, attending department meetings, and writing proposals are normally included as indirect costs (aka facilities and administrative costs) and should not be charged or cost shared on sponsored projects as direct costs.
Effort reports and the effort reporting process are regularly audited. The risks of non-compliance include:
- False Claims Act liability
- Direct cost refunds to sponsor
- Jeopardizing future funding
- Jeopardizing CSU’s status as a low-risk auditee
- Potential personal criminal charges
For faculty and exempt Administrative Professionals, Institutional Effort (or 100% effort) represents all effort among all of the duties for which an employee is compensated (aka Institutional Base Salary (IBS)).
Institutional effort is not based on a defined number of hours, but represents the total time spent on University work within the scope of an individual’s appointment. Total institutional effort will always equal 100% even if the individual’s appointment is for less than 1.0 FTE.
Federal regulations allow for small amounts of time spent on incidental activities (also referred to as de minimis effort) to be excluded from the measurement of Institutional Effort. CSU considers incidental activities to be activities that are non-routine, nonrecurring, and together less than 1% during any month or pay period.
In most instances, the Principal Investigator(s) is responsible for certifying for all employees who have salary directly charged or cost-shared on each sponsored project. This includes, faculty, state classified personnel, graduate assistants, students, and administrative professionals.
There are circumstances when it may be appropriate for the PI to designate this responsibility to another individual associated with the project. When certifying, PIs or their designees are attesting that they have sufficient technical knowledge and/or are in a position that provides for suitable means of verification that the work was performed.
Certifiers should review charges on awards on a routine basis and identify any effort-related changes and communicate significant changes to the Department Effort Coordinator.
‘Suitable means of effort verification’ includes first-hand knowledge of work performed. Knowledge must be sufficient to support a reasonable estimate of effort expended such as calendars, logbooks, and timesheets.
An auditor may reconcile an individual’s certified effort against progress reports, calendar entries, lab books, email correspondence, or proposal submission/technical reporting portal activity.
Charging 100% effort to sponsored projects indicates that an individual did not work on anything but those projects during a given period. Generally, faculty cannot commit 100% of their effort to sponsored projects, as time must be reserved for other CSU duties such as teaching, advising students, attending department/college meetings, serving on committees, writing proposals, summer vacation, etc.
Administrative Professionals and Classified staff may devote up to 100% effort to sponsored projects, however, the allocation of effort must be reasonable given the individual’s non-sponsored University activities.
This answer often depends on the details of an individual’s academic appointment. Things like bonuses, one-time payments (honoraria), supplemental pay, external consulting, and community volunteer work are generally not part of 100% effort.
Any individual listed as a Key Personnel on an award is expected to contribute to the scientific development or execution of the project in a substantive and measurable way. Failure to document at least one percent effort for Key Personnel may indicate to the sponsor that the individual did not provide the necessary contribution(s) or work on the project.
Key personnel includes anyone listed as a PI, Co‐I, or other key person. CSU’s effort policy defines this as the program director/principal investigator and other individuals who are responsible for the scientific design, conduct, and execution of a project in a substantive and measurable way, whether or not they request salaries for compensation. This does not include individuals who fall under the NIH classification of Other Significant Contributors and are presented at “zero person months” or “as needed.” Per NIH guidance, individuals with measurable effort may not be listed as Other Significant Contributors.
The sponsor does not reimburse faculty salary: Yes, Key Personnel must devote at least one percent effort even if the sponsor will not reimburse CSU for those costs. If there is a match requirement, those costs should be included in the proposal as cost share (if allowable). If the sponsor does not reimburse faculty salary and does not require cost share, the one percent effort should not be quantified in the proposal but will still need to be tracked internally. The salary should be treated as non‐reportable cost share and the 1% minimum effort should be captured in a companion cost share account. See the ‘1% Minimum Effort Cost-Share Account Request’ form.
Equipment Acquisition grants: No*
Equipment/Instrument Development grants: Yes, the PI is required to provide oversight of their lab staff as they develop the new research instrument. Therefore, at least a one percent effort commitment should be captured.
Dissertation grants: No*
Conference/Workshop Support grants: No*
Travel grants: No*
Participant Support Accounts: No*
Program Income Accounts: No
Individual Fellowship/Scholarship awards: No*
Research grants (not fellowships) for research work primarily being done by a graduate student: Yes, the individual serving as PI is still expected to provide some level of effort for overseeing the project, advising, and facilitating research deliverables.
Institutional Training grants: Yes, the Training Program Director/Principal Investigator is responsible for the selection/appointment of trainees and the advisory committee (when applicable), and for the overall direction, management, administration, and evaluation of the program. The Training PD/PI is also expected to monitor and assess the program and submit all documents and reports as required.
Institutional Research Experiences for Undergraduates (REU) programs: Yes, the Program Director/Principal Investigator is responsible for overseeing all aspects of the award.
Research Experiences for Undergraduates (REU) supplements: No, the PI/Co‐I should already have some level of committed effort on the parent research project.
The Department Chair (or another individual) is serving as the PI as part of Conflict of Interest management: Yes, the individual serving as PI is still expected to provide at least the minimum level of effort for their part in overseeing the financial and technical aspects of the project.
No Cost Extensions for the basic purpose of closing out the award: No
No Cost Extensions where substantive work must still be completed: Yes **
*Unless the sponsor guidelines or award terms require PI effort. For instance, some fellowship applications require that the faculty mentor provide a Current and Pending Support document in the proposal and that they include THIS proposal and their de minimis effort on it for overseeing the fellow.
**For NCEs if the PI and other Key Personnel on the project will not be charging at least the de minimis 1% effort to the sponsored project account, an NR-CSA must be created, or if one already exists it must be updated, to capture their de minimis 1% effort during the NCE period.