By Daniel Sierra, Senior Compliance Manager, Office of Research Compliance
Per (2CFR), § 200.430, UCF is required to have a system in place for certifying the allocation of time and effort associated with sponsored research, training, and service awards. UCF must comply with federal requirements for certifying time and effort expended on sponsored awards, to encompass all employee activities (100%). In compliance with these standards, this policy establishes the requirements of and procedures for recording, monitoring, and reporting time and effort certification.
The Office of Research manages the university’s time and effort certification process; provides a certification reporting system to monitor, track and account for individuals’ time and effort certification affirmations; and provides policies, procedures, and training on time and effort certification reporting.
As UCF innovated and updated its enterprise management to the Workday system, we identified a need to review and renew our Employee Compensation Compliance (ECC) system and the associated Time and Effort Certification Policy. For research institutions, it is critical to mitigate the institutional risks associated with noncompliant documentation of personnel costs. With the latest updates to the ECC system and the university’s Time and Effort Policy, UCF can more effectively manage time and effort certification and payroll confirmation. We believe we will achieve this goal with the help of four points of emphasis in the updated Time and Effort Certification Policy:
- Having a certification system in place that reflects new changes in association with the Workday transition.
- Emphasis on directly charging time and effort to sponsored awards and a requirement for a minimum level of effort of one percent (1.0%).
- Emphasis on time and effort expended on sponsored awards and cost shared by the university to be properly accounted for by charging a cost share grant.
- A new Compensation Reporting course, which provides an overview of the federal requirements of time and effort reporting (CITI Program)
With the update to Workday, there has been a plethora of changes to background information as it relates to sponsored awards. The ECC system required a complete overhaul to accurately reflect the transition from PeopleSoft to Workday. These changes include updates to sponsored award/grant number associations, background employee information and overall data integration of Workday to ECC.
The updated Time and Effort Certification Policy also emphasizes the requirement for university employees to have their time and effort to sponsored awards allocated based on actual committed effort expended on all sponsored activities they perform. The expended time and effort must be allocated to the award where the work was performed and must be allowable per the award. In the instance of multiple awards, time and effort must be allocated to reflect the time spent on each funded project and other university assignments. Principal Investigators are responsible for ensuring that the effort of their students and employees is assigned to the award where the work was performed and must ensure that inappropriate charges are not placed on an award.
We want to continue to expand on meeting and maintaining federal requirements as they relate to personnel and sponsored research. This updated Time and Effort Policy highlights the requirement for employees providing time and effort to a sponsored award(s) to charge and certify their time directly to the sponsored award(s) and/or an associated cost share grant.
Whether direct-charged, or allocated to a cost share grant, the commitments proposed by faculty and staff must be properly allocated per the award, federal regulations, and university policy; and must be entered for the period in which the sponsored activity was conducted.
Our last point of emphasis is a focus on training and education as it relates to time and effort certification. Employees working on sponsored awards must complete time and effort certification training prior to award/grant set-up and repeat the training no less than once every four (4) years. This will be accomplished with CITI Program’s Compensation Reporting module, which includes overviews of the following:
- Compensation and Parameters for Personal Services
- Compensation Reporting Best Practices for Faculty and Administrators
- Compensation Reporting Requirements
- Documentation Requirements for Compensation Reporting
- Introduction to Compensation Reporting
With the changes outlined above, our goal is to continue to meet federal, university, and sponsored award policies and regulations.
For more information related to the Time and Effort Certification Policy, please email Daniel Sierra, Office of Research – Compliance at Daniel.Sierra@ucf.edu.