Authority: Vice Chancellor for Finance and Administration
History: First Issued: January 1, 2002. Last Revised: July 22, 2011.
Contact Info: Assistant Director, Systems and Compliance (919-515-8011) Office of Contracts and Grants.
1.1 As a recipient of federal contract and grant funds, the University is responsible for maintaining an effort reporting system in compliance with the requirements of OMB Circular A-21, section J(10). This system must document all effort, whether treated as direct or F&A, for sponsored agreements. Of the options available, NCSU has chosen the “Plan-Confirmation” method.
1.2 Under the “Plan-Confirmation” method A-21 states “the distribution of salaries and wages of professional and professional staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity, updated to reflect any significant changes in work distribution. At least annually, a statement will be signed by the employee, principal investigator, or responsible official(s), using suitable means of verification that the work was performed.”
2. THE TEARS SYSTEM
2.1 The TEARS System is a web-based system that provides the mechanism to document effort performed on sponsored research projects. The application provides departmental personnel with the means to setup cost shared effort for principal investigators and others working on sponsored projects. This system conforms to the requirements for documenting such effort for the University as required by OMB Circular A-21. The system, and information contained therein, will also provide the information necessary to report cost sharing on externally funded sponsored projects, as well as provide documentation necessary for the Facilities and Administrative (F&A) Cost Proposal. The TEARS System can be accessed by logging into the MyPack Portal and clicking on the link for “Employee Self Service”, or the TEARS link under the Human Resources Systems menu. The TEARS System Users Manual can be found athttp://www.ncsu.edu/cng/tears/TEARS_user_manual.pdf.
3.1 Office of Contracts and Grants Responsibilities
3.1.1 Establishing internal and campus procedures for effort reporting which are consistent with the requirements of OMB Circular A-21;
3.1.2 Producing effort reports on a periodic basis and distributing them to the colleges for employee review and certification;
3.1.3 Retaining all certified effort reports for audit purposes;
3.1.4 Monitoring College responsibilities related to effort reporting to ensure University compliance;
3.1.5 Providing assistance to College business officers, College TEARS coordinators and University employees with effort reports; and,
3.1.6 Ensuring that the effort reporting system is functioning in accordance with Federal regulations.
3.2 College Responsibilities
3.2.1 Establishing personnel actions for monthly-paid employees in the University payroll system on a timely, prospective basis to ensure accurate payroll charges to sponsored projects based on actual work activities to be performed by employees.
3.2.2 Ensuring that employees working on sponsored projects as part of the University’s cost sharing commitment and employees spending significant amounts of time on sponsored projects are scheduled to receive effort reports.
3.2.3 The timely review, adjustment and certification of effort reports in compliance with Federal deadlines. Ninety (90) days are allowed after the end of each TEARS survey period for the review, adjustment and certification of effort.
3.2.4 Coordinating retroactive payroll adjustments affecting sponsored projects or other pay sources for subject employees with the effort certification process to ensure that all adjustments to effort reports and related payroll charges are completed within the ninety (90)-day period allowed for changes.
3.2.5 Monitoring and maintaining committed levels of effort on sponsored projects.
4. EMPLOYEES SUBJECT TO EFFORT REPORTING
Employees subject to effort reporting requirements are those who:
4.1 Work on sponsored projects for which the sponsor reimburses the University.
4.2 Work on sponsored projects but whose time on the project is funded by the University. The University’s contribution to the cost of the project is referred to as cost sharing.
4.3 Are paid from certain federal appropriations made to Land-Grant Universities. For more information on federal appropriated accounts subject to TEARS, please go to http://www.ncsu.edu/cng/index.php and click on the TEARS link.
5. SURVEY PERIODS
5.1 Survey periods are the federally approved time periods for which employee effort must be certified. Survey periods consist of multiple months and are intended to generally coincide with the University’s Fiscal year and summer period.
5.2 Employee classifications (9-month EHRA, 12-month EHRA or SHRA) determine the survey periods applicable to their effort reports.
5.3 Survey periods, based on employee classification, are as follows:
5.3.1 12-month EHRA and SHRA employees:
184.108.40.206 Fiscal year – 07/01 through 06/30
5.3.2 9-month EHRA employees:
220.127.116.11 Fiscal year – 08/16 through 05/15
18.104.22.168 (Because 9-month contract EHRA employees are reimbursed for their academic year work over the 12-month fiscal year (i.e., they receive 12 monthly payroll checks instead of 9), effort percentages for the Fiscal year effort report include regular payroll charges for months not indicated by the survey period. Payroll charges for the months of May through August are included in the Fiscal year effort report.)
5.3.3 Supplemental summer period – 05/16 through 08/15
22.214.171.124 (Supplemental payments to faculty incurred in the University’s payroll system from May through September are included on special effort reports that are prepared for 9-month EHRA faculty who work on contracts and grants during the summer months.)
6. REVIEW AND CERTIFICATION
6.1 Review the percentages under Projected % by section. Determine if the percentages are a reasonable approximation of actual effort expended for each activity during the survey period indicated.
6.2 If any of the percentages under Projected % are significantly different from how effort was actually expended during the Survey Period, contact the Department or College TEARS Coordinator to update the Adjusted Effort % column. If adjustments are necessary, all of the effort must be restated in the Adjusted Effort % column so that the column totals 100%.
6.3 If the percentages of effort for each project and category appear to be reasonable, the employee should electronically certify the effort report. Please note that your signature is certifying the effort in the Adjusted Effort % column if you make any adjustments. Employees should review and certify their own effort report when available to do so. The department head, College Dean or designee may also perform review and certification. However, A-21 requires anyone certifying the report to use “suitable means of verification that the work was performed.” It is important that anyone certifying in lieu of the employee has first-hand knowledge of their work activities during the survey period and be able to meet A-21 requirements. In any audit situation it would be the responsibility of the person certifying the effort report to support that all certification requirements were met.
6.4 Effort reports must be certified by the deadline indicated on the top of the report. This deadline is 90 days after the end of the effort reporting period.
7. COST SHARING
7.1 Cost sharing represents resources provided by the University that directly benefit sponsored projects. Cost shared effort is defined as work performed by employees on sponsored projects that is not paid by the sponsor. Cost shared effort should be included on the effort report as it is a component of the total effort an employee works.
7.2 Certain situations involving cost shared effort cannot or should not be documented on effort reports:
7.2.1 Cost sharing funded by another sponsored project.
7.2.2 Cost sharing funded from federal appropriations.
7.2.3 Cost sharing performed by bi-weekly paid employees.
7.2.4 Cost sharing performed by 9-month EHRA employees during the summer period May 16 through August 15.
7.3 In each of these cases an After the Fact Memo is required to document cost sharing.
8. COORDINATION OF EFFORT REPORTS AND LABOR ADJUSTMENTS
8.1 Personnel actions, retroactive labor adjustments and effort reports are related because:
8.1.1 Personnel actions establish pay sources (account number and object code) and the amounts to be funded from each source in the University’s payroll system for employees who are paid on a monthly basis.
8.1.2 Retroactive payroll adjustments move payroll charges for the current or a previous month from the pay source originally charged to another pay source.
8.1.3 Effort percentages and account numbers appearing in Sections A and D of effort reports are based on pay sources and amounts established in the University’s payroll system by personnel actions and adjustments to those pay sources or amounts by retroactive payroll adjustments.
8.2 When personnel actions and related retroactive payroll adjustments affecting monthly payrolls included in a TEARS survey period are processed after effort reports for that survey period have been created, the percentages printed on the effort report no longer agree with the adjusted labor charges.
8.3 Personnel actions and retroactive labor adjustments which affect labor charges for months included in a survey period that are processed after the effort reports for that survey period are created do not automatically change effort percentages. For this reason it is necessary to coordinate retroactive personnel actions and related retroactive labor adjustments affecting contract and grant projects with the distribution, review and certification of effort reports.
8.4 Retroactive labor adjustments that affect contract and grant projects must be completed and processed within the ninety (90)-day period after the end of the applicable academic period.