What is Employee Compensation Compliance?

Employee Compensation Compliance (previously referred to as effort reporting) is a requirement of OMB Uniform Guidance and is applicable to all federal and federal flow-thru (including state funded federal flow-thru) grants. It may also be a condition of some nonfederal cost sharing and matching agreements.

The process is the Research Foundation's means of

  • complying with the federal regulations
  • providing assurance to sponsors that salaries and/or cost sharing is charged to sponsored projects are reasonable in relation to the work performed
  • ensuring that faculty and staff have met their commitments to sponsored projects

Failure to certify effort correctly and in a timely manner could

  • jeopardize Buffalo State’s Federal research funding
  • result in sponsor disallowances if the RF cannot document that an employee required to certify effort is devoting the required amount of effort to the appropriate project(s)
  • be subject to fines if it is found that effort reports have been erroneously certified

RF employees certify their effort electronically in the ECC.

Who Has to Certify Effort?

  • If your salary is charged in whole or in part directly to a sponsored award funded with federal or federal flow-through dollars, you must certify your effort.
  • If you expend committed effort on a sponsored project, even though no part of your salary is charged to the award, but rather it is being cost-shared by the institution, you must certify your effort.

It is the preference at Buffalo State that University personnel certify their own effort, as the individual is in the best position to determine the amount of effort they have devoted to a particular award(s). However, in cases where the individual is unavailable for signature, the Principal Investigator or other award staff who has firsthand knowledge of the amount of time the individual devoted to a particular award, can sign on their behalf.

Frequently Asked Questions

Completion of an effort certification is necessary for the Research Foundation to comply with the provisions of OMB Uniform Guidance, which requires that institutions receiving federal funds keep an accounting of the distribution of personnel effort allocated to federally sponsored awards. There are three reasons why you would receive an effort report to certify. Either you are a Research Foundation employee being paid directly from a federally funded award, you are a SUNY employee who is paid through an IFR, or you are cost sharing on an RF funded award. For SUNY employees who are cost sharing, the effort certification process provides the needed documentation that the institution has met its cost share obligation.

Award number 000264 is the Other Institutional Activity (OIA) account. This award tracks all of your effort that is NOT related to a sponsored program activity. So, for instance, if you are a full time SUNY employee and 10% of your effort is dedicated to a sponsored award, then since the University is paying your salary, that 10% constitutes cost sharing on the part of the institution. In this example your effort report would indicate the 10% to the specific sponsored award number to which you are assigned and 90% to Other Institutional Activity award 000264.

It is possible that the award number on the effort report may not be familiar to you or that an abbreviated title or short name of the award might appear on the effort report (e.g., HRA02, OTSST5). Therefore, the fact that you might not recognize the information on the effort report may not necessarily mean that you did not provide services to the award. Call Dale Bessinger, our cost sharing/effort reporting specialist, at 716-878-5079, and he will be glad to clarify any information that appears on the effort report form.

Federal regulations require that you certify the actual effort provided to the award, not the estimated amount that was determined at the time the proposal was submitted. The Research Foundation uses the information on the certified effort report to bill and account for institutional cost sharing provided by SUNY employees, and to verify that RF employees are allocated to the correct awards. Certifying effort at a higher percentage (more than 5%) of what you actually provided to the award can result in overcharging the federal government, which if found in an audit, could result in stiff penalties to the RF.

So, in instances where you feel that the effort is overstated (or understated for that matter), contact the Grants Management office so that a review can be done and the appropriate corrections made.

In instances where you feel that the effort is overstated (or understated for that matter), contact the Grants Management office so that a review can be done and the appropriate corrections made. Your records will then be updated in the accounting system. If you do not contact us, the changes will not be made and your certification will continue to appear as delinquent.

The Sponsored Programs Grants Management Department is responsible for overseeing the effort certification process. If you have questions or concerns related to your effort report specifically, or the effort report process in general, you can contact Dale Bessinger, the Grant Administrator responsible for effort reporting on our campus.