Definitions

Faculty effort is the time that faculty spend on instruction, research, administration, service, and clinical activity.

Faculty Effort Certification (FEC) reports are quarterly or semi-annual forms faculty members complete to document their actual effort, both paid and cost shared, on grants and contracts. A faculty member receives an FEC if he/she is paid by the University of Washington and:

• Performs effort paid on Federal and Non-Federal sponsored projects, which include grants and contracts, and/or
• Performs cost sharing on Federal and Non-Federal sponsored projects, which include grants and contracts.

The purpose of the FEC is to certify that percentage distribution of pay is a reasonable reflection of actual effort.

Note: Non-faculty personnel, such as professional staff, senior fellows, lab technicians, and others, do not receive FECs. Their effort is reported on monthly Grant and Contract Certification Reports or as otherwise agreed by the University. These monthly reports are subject to the same audit requirements as FECs.

Cost sharing is a requirement by a sponsor (usually Federal) that the University share in the cost of research. For instance, if the total cost of a project is $150,000, the sponsor might award $100,000 and require that the University provide the additional $50,000 from non-federal funding sources. Alternatively, the PI may have committed $50,000 of cost share in the proposal even though it was not a sponsor requirement. After cost sharing is committed in a proposal, actual cost sharing must be provided and documented or the sponsor can reduce the award to compensate for th e unmet cost sharing. In this case expenditures exceeding the reduced award become a de ficit for which the PI is responsible.

Effort that is cost shared is subject to the same requirements as salary that is paid directly from the grant or contract.

There are four types of cost sharing:

• Mandatory: Cost sharing that is required as a condition of the award (normally, but not always federal) or that, in the case of contracts, was agreed to between the University and the sponsor in the contract negotiation.
• Committed: Cost sharing not required by the sponsor that includes and quantifies monetary contributions and/or effort in the sponsored project proposal budget or budget justification with no corresponding funding requested or awarded. Once this type of cost sharing is offered and the grant or contract is awarded, the cost sharing is required to be documented.
• Aggregate: Cost sharing that is required by the National Science Foundation (NSF) to fulfill the requirement that the University provide an amassed one percent (1%) cost sharing on NSF unsolicited awards. It has been announced by NSF that program-specific and 1% aggregate cost share requirements on unsolicited awards will be phased out. Awards issued before June 1, 2007 will continue to carry the 1% requirement or may have program-specific cost sharing requirements that must be met.
• Salary Cap: Cost sharing for faculty who exceed the federally mandated salary cap. It is required by:
  • National Institute of Health (NIH)
  • Substance Abuse and Mental Health Services Administration (SAMHSA)
  • Agency for Healthcare Research and Quality (AHRQ)
• K Awards: Cost sharing that may be required if the paid effort does not satisfy the effort requirement, usually 75%, for mentored awards.

Note: Any effort performed that was not placed on the budget page or budget justification of the proposal is considered "voluntary uncommitted effort" and is not documented separately.

Why Faculty Need to Complete the FEC

The Federal government requires signed documentation for faculty salary costs charged to grants and contracts and for cost sharing related to sponsored agreements. Sponsored agreements include grants and contracts.

Office of Management and Budget (OMB) A-21, "Cost Principles for Educational Institutions" requires faculty involved in sponsored agreements to report activities for which they are compensated each academic term or no less often than every six months, and to account for mandatory and committed cost sharing that was placed on the proposal budget page or budget justification, and any salary cap cost sharing, be documented on the FEC. The FEC reflects an after-the-fact-reporting for faculty effort, paid and cost shared.

What are the Compliance Risks

Recent audits resulting in multi-million dollar settlements between the government and research institutions, coupled with policy changes at the national level, have resulted in an increased level of risk to effort reporting.

Improper or inadequate certification of effort can result in the following restrictions imposed on the University by the federal government:

• Payback of award funds to sponsor
• Withholding of future awards
• Special monitoring by sponsor
• Temporary withholding of payments
• Audit findings
• Requirement for corrective action plan
• Designation as a "high risk" organization
• Loss of Expanded Authorities
• Payment of punitive damages

How the FEC Form Is Used

The FEC is used:

• In audit and compliance:
  • Faculty Effort Certification reports are used in the audit process, to ensure compliance with the level of effort agreed to in the award document, and/or to determine cost sharing
  effort.
  • Ensures compliance with the OMB Circular A-21requirement to confirm that the distribution of effort "represents a reasonable estimate of the work performed by the employee during the period."
  • FECs are reviewed by:
    • Granting Agencies
    • The University of Washington, Internal Audit
    • State Agencies/Auditors
    • Federal Government Agencies/Auditors
• To show salary information and amounts available as a cost share source.
  • FECs provide departments with the monthly average salary for a quarter by budget source for a given individual, and specify the Non-Federal budget amounts available for cost sharing.
• To certify that the faculty have performed the sponsored project work for which they are paid.
  • Sponsors expect the FEC to provide verification that the compensation charged is appropriate to the activity performed.
• To document the faculty effort cost sharing included in the Facilities and Administrative (indirect cost) proposal for the University.
• To complete the final report to the sponsor prepared by Grant and Contract Accounting (GCA).

Note:The FEC report is considered a public record under the terms of the State of Washington's Public Disclosure Act.

Process Overview

Individual faculty members and department FEC coordinators are primarily responsible for accurate completion of Faculty Effort Certification reports and necessary adjustments to salary charges and cost sharing resulting from faculty reported effort.

Management Accounting and Analysis is responsible for the timely distribution, collection, and review of FEC reports to ensure compliance with federal regulations.

Printing the FECs

FECs are printed quarterly and semi-annually as determined by individual College or School administrators and reflect salary and effort for the prior quarter.

• Quarter Dates:
  • Winter: 12-16 to 3-15
  • Spring: 3-16 to 6-15
  • Summer: 6-16 to 9-15
  • Autumn: 9-16 to 12-15
• Semi-Annual Dates:
  • 1-1 to 6-30
  • 7-1 to 12-31

Computing and Communications prints the quarterly FECs. Management Accounting and Analysis (MAA) prints the semi-annual FECs.

Faculty members who receive an FEC are by selected by:

• object code 01-10 for instruction and research faculty salaries (full and part time, permanent and temporary instruction and research personnel)
• and occupation codes between 0001-0147 and 0151-0180,
• or occupation codes between 0181-0199 with TFA (Retired Exempt Pay).
• AND, faculty must satisfy at least one of the following criteria for the FEC reporting cycle:
  • have been paid on a grant or contract (budget type 05),
  • have a mandatory cost share agreement,
  • have committed cost sharing where funding is shown on the sponsored project proposal budget or budget justification with no corresponding funding requested or awarded,
  • have a National Science Foundation (NSF) grant with an aggregate cost share requirement.

Note: Budget type/class 05-57 (royalty), 05-52 (clinical income), and 05-45 (staff assignments and service contracts) are not considered sponsored activity and do not in themselves qualify for printing an FEC. These budgets will appear on effort reports when the faculty member is paid on sponsored agreements or has a cost share pledge or commitment.

Once faculty members are selected, the system collects information for each FEC from three of the online administrative systems:

• HEPPS payroll history file for quarterly reports and the HEPPS data warehouse for the semi-annual reports. (Earn types REG, SUM, PLP, TFA, ADS, and ENS salaries are included)
• FIN (budget name, budget type, organization code)
• BGT (cost share pledges)

Distribution of the FECs

MAA distributes the FECs to the departmental FEC Coordinators

• by organization code and
• by the individual's home department as listed in HEPPS

Review and Certification

• Department coordinators should first check the accuracy of the salary data on the FECs, correct any errors or omissions on the form by hand and in ink, and attach appropriate documentation.
• The department coordinator then sends the FEC to the faculty member whose name is on the FEC. The faculty member reviews the salary information, completes the effort section, and signs and dates the FEC form.
• The faculty member returns the completed and signed form to the person coordinating FEC completion in the department.

Signature

The faculty member whose name is on the form signs the FEC. In exceptional circumstances the Chair or Dean may sign when they have knowledge of and can verify that the work was performed. The department FEC coordinator should always send an informational copy to the faculty member

If the faculty member is unavailable (i.e., not on campus) to sign the FEC, there are some alternative methods the department can use to secure confirmation by the employee.

1. Send the FEC by mail or FAX for review and signature and have the employee confirm the effort, sign and return the form by U.S. or campus mail.
2. Send the FEC by email, have the employee respond by return email to the chair or dean that the effort information on the form is correct. The chair or dean can use the email as a suitable means of verification that the work was performed and provide the in ink signature. The department should keep a copy of the email in the department files.

Records Retention

• The department makes a copy for their files and returns the original completed form to the Office of Management Accounting and Analysis (MAA), Box 351248.
• The department keeps copies of the FECs for their faculty for one year after the end of the fiscal year. (See the General Records Retention Schedule.)
• MAA keeps copies in their office for 6 years after the end of the fiscal year per the same General Records Retention Schedule.

Blank FECs

Occasionally, a faculty member will not receive a preprinted FEC, but will still be required to certify effort. Most commonly this situation arises when faculty members who are not paid on grants are added to a cost share commitment or when faculty members who are not performing research receive a new award that did not get set up before the FEC was printed. In these situations, a blank FEC is required. To request a blank FEC, follow the instructions below.

• Send an email request to suzette@u.washington.edu with the following information and a form will be emailed to you:
  • College code and name
  • Department organization code and name
  • Mailbox #
  • EID and Faculty name
  • Job class code and title
  • Begin and end date of the cycle
  • Total FTE%

NOTE: When preparing a blank, one of the following must be attached to the FEC for documentation of salary:

• HEPPS Funding History, screen 3/35 with the exact cycle dates, or
• OPUS "Funding History" screen shots with the exact cycle date

Follow-up Process

The review, certification (signing), and return of FEC reports must be accomplished in a timely manner. FECs must be signed and dated by the faculty member by the "Complete By" date and returned to MAA.

• To ensure that they are received in a timely manner, it is recommended that the forms be sent through campus mail promptly after the faculty member has signed them. Additional time may be required for forms coming from off campus.
• It is a good idea, though not required, for faculty to sign the FEC and immediately return the FEC to MAA two weeks before the deadline. This ensures that there is sufficient time to make any needed corrections or clarifications.

Approved Extensions

The department may request an extension for the following reasons:

1. Awaiting receipt of a late award
2. Waiting for OSP to create a new NEA
3. Awaiting approval for a no cost extension

All other requests will be handled on a case-by-case basis.

The requests for an extension should be in an email to MAA and include the following information:

• Faculty name(s)
• Department
• Cycle dates of FEC(s)
• Reason for delay (i.e. A, B, or C from above)
• Requested extended due date

Follow-up Timetable

The follow-up timetable has five steps. The dates for these steps appear for each reporting cycle at the top of the FEC web page.

1. MAA will send an email reminder to all FEC coordinators and department administrators approximately 2 weeks prior to the "Complete By" date.
   • This is an automated email that is sent to all FEC coordinators and administrators. You will receive this email regardless of FEC status.
2. The "Pending Correction or Not received " report will be sent to the FEC Coordinator and the department administrator approximately 3 working days following the "Complete By" date.
   • Copies of this report, which lists all faculty members whose forms have not been received in MAA or were signed and received by MAA but were returned to the department for correction, will also be sent to the department chair, the school or college administrator, and the affected faculty member.
3. The department will have two weeks to return these reports, after which a second reminder will be sent to the department Chair (or Dean if there is no Chair) listing faculty whose FEC reports continue to be outstanding.
   • Copies of this report will also be sent to the department FEC coordinator, department administrator, school or college administrator, the Dean or an approved designee at the Vice President level, and the affected faculty member.
4. Approximately 4 weeks following the "Complete By" date, the Dean or the approved designee will receive a letter stating that MAA has requested all charges be removed from the grant(s).
   • Copies of this report will also be sent to the department FEC coordinator, department administrator, school or college administrator, and the affected faculty member.
5. Departments will remove the charges from the grant(s) and return the unsigned FEC and RST to MAA.

Management Accounting and Analysis
A department of Financial Management
Modified: April 11, 2008