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Research Management Operating Procedure Effort Certification Effort Certification Summary: The effort certification process involves the distribution of effort certification forms (also known as effort reports), pre-review by department, division, or center administrators (“Administrators”), certification by investigators, and return of effort certifications to the Partners Effort Certification Team. Effort certification forms are generated off of the payroll system in order to show how salary was charged during the effort reporting period. The purpose of the effort report is to:  Report reasonable estimates of the percent distribution of time spent on each organized research project and other activities engaged on behalf of Partners (i.e. patient care, instruction & training, and administration)  Confirm that the salary charges are appropriate for the effort that is being certified; if incorrect, indicate how the salary allocation should be changed to make it consistent with effort  Identify other areas where effort was provided, including effort with no salary support  Provide supporting documentation for Investigator salary charges to sponsored research projects to assist in satisfying federal (45 CFR Part 74) and sponsor reporting requirements  Serve as a source of information as to whether effort commitments to sponsors are being met. The completed effort certification should only reflect activities conducted under the terms of an individual’s employment at a Partners’ institution and for which they receive Partners compensation. Outside consulting, activities at other institutions not covered by the Investigator’s hospital/professional organization salary, stipend payments, bonus (special pay) payments, or De Minimis Effort should not be included in the effort report. In addition, the Total Partners Professional Effort should also sum to 100%. The following guidelines were developed by the Research Management Effort Certification Team to document the procedures that must be followed when processing effort certifications. Revised November 18, 2008 1 Research Management Operating Procedure Effort Certification Roles and Responsibilities: Investigators       Administrators  (Dept / Div / Ctr Administrators)        Revised November 18, 2008 Review and certify their personal effort distributions for all organized research activities at each Partners’ institution for which they provide services. Monitor paid and unpaid effort (cost sharing commitments must be approved and documented by the Institution - see the Partners Cost Sharing Policy). Identify needed corrections and work with Administrators to effectuate necessary changes. Recertify effort reports as may be necessary (See Partners Effort Recertification Procedure). Work with their Administrator and the Partners Grant & Contracts PostAwards Team to seek prior approval from federal sponsors for Significant Changes in Work Activity (i.e. if they expect to reduce their effort on any sponsored project by 25% or more, plan to withdraw from a sponsored project, or will be absent from Partners for more than three months (shorter period of time for some sponsors). Where Investigators do not have a designated administrator to manage effort reporting, Investigators are also responsible for fulfilling the administrator role as described below. Assist with the review and approval of effort distribution reports for organized research and other hospital activities at the Partners’ institution. Assist the Investigators with reviewing and approving their effort distributions. Assist the Investigators with identifying needed corrections and effectuating necessary changes. Retain copies of certified effort certifications and return to the Partners Effort Certification Team. Assist with recertification of effort reports as may be necessary (See Partners Effort Recertification Procedure). Track Investigators’ effort commitments to sponsored research and other institutional activities (including patient care, instruction and training, and administration) Confirm effort distributions meet sponsor and institutional effort commitments. Work with Investigators and the Partners Grant & Contracts PostAwards Team to seek prior approval from federal sponsors for Significant Changes in Work Activity (i.e. if they expect to reduce their effort on any sponsored project by 25% or more, plan to withdraw from a sponsored project, or will be absent from Partners for more than three months (shorter period of time for some sponsors). 2 Research Management Operating Procedure Effort Certification   Effort Certification Team Monitor and maintain effort reporting compliance for their service Update the Partners Effort Certification Team with changes to points of contact for effort reporting.  Assist the Investigator and Administrator in identifying salary and effort adjustments, if needed. Distribute effort certification forms to the research community on a timely basis. Distribute effort recertification forms as may be necessary. Identify and follow-up with those who do not timely submit completed reports. Retain certified and recertified effort reports (on file or electronic storage).     Grants and Contracts   Assist Investigators and Administrators to seek approval from federal sponsors if they expect to have Significant Changes in Work Activity (i.e. if they expect to reduce their effort on any sponsored project by 25% or more, plan to withdraw from a sponsored project, or will be absent from Partners for more than three months (shorter period of time for some sponsors). Assist Investigators and Administrators with the review and approval of cost transfers and supporting documentation associated with retroactive salary adjustments to previously certified effort reports (see Partners Cost Transfer Policy). Process: Certifying Effort Reports 1. 2. At the time a proposal is submitted and/or at the time that the project is awarded, Administrator and the Principal Investigator will review the effort declared on the grant application and Other Support Page (submitted as part of the Just-In-Time process) for all Investigators on the project to ensure that there are no conflicts of effort committed. The NIH Guide states that “zero percent” effort or effort “as needed” is not an acceptable level of involvement for Key Personnel. If there are conflicts, they must be resolved before that person’s salary and fringe benefits can be charged to the sponsored project. [Note: Some sponsors require all potential effort conflicts to be resolved at the time a grant application is submitted to the sponsor for review. Most sponsors, however, require that effort conflicts be resolved when a grant is awarded. Refer to your sponsor’s requirements for more information]. At the end of each reporting period, the Partners Effort Certification Team will create effort certification forms for all Investigators and have them distributed to the applicable Administrators (or directly to Principal Investigators who have no designated Administrator). Revised November 18, 2008 3 Research Management Operating Procedure 3. 4. Effort Certification The Administrators will then pre-review the report forms. As part of their review, administrators will: a. Verify that they have received effort certification forms for all investigators they manage. If they are missing any forms, email the Partners Effort Certification Team (phseffort@partners.org) with a list of missing investigators along with their institution name, department, and chief code. Likewise, if they have received forms for investigators they do not manage or are not associated with their department / division, notify the Partners Effort Certification Team. b. Return effort certification forms for T32 trainees, F32 trainees, non-research personnel, or investigators who receive absolutely no compensation from Partners unsigned and with notations explaining their research status (e.g. ‘T32 Trainee’) to the Partners Effort Certification Team (Partners Research - Effort Reporting, 101 Huntington St., Suite 210, Boston, MA 02199). c. For investigators they do manage and are non-exempt from certifying effort reports, verify that all funds are listed and correct. If funds are missing or incorrect, document the correct cost center, fund description, fund #, project period, and % effort allocated to the fund. Include awards where fund #’s are still being set up; note ‘fund # in setup’ and update the Partners Effort Certification team when the fund # has been created. d. Review the salary charges to sponsored project accounts to ensure that they are consistent with the preprinted effort percentages for the applicable reporting period. If salary distributions need to be corrected or erroneous payroll charges are hitting funds, contact the investigator’s payroll manager to initiate an electronic data change (EDC) in the payroll system to redistribute expenses to the appropriate funds (See Partners Cost Transfer Policy and Partners Employee Data Changes Procedure). e. Make necessary adjustments for expected effort commitments without salary support resulting in cost sharing, salary over the cap, or other corrective measures; note those adjustments on the effort certification forms (e.g. ‘cost sharing’, ‘redistribution of salary over the cap’). f. Confirm that the effort listed on the effort certification forms are consistent with the effort committed in any sponsored project applications or proposals, or consistent with any changes in effort approved by the sponsors. If there are any Significant Changes in Effort, notify the Partners Grants & Contracts Post Award Team as soon as anticipated to obtain prior approval from the sponsor. g. Provide the updated effort certification forms to their Investigators for review and certification. If an investigator has since left the institution, provide the updated effort certification form to a responsible individual having first-hand knowledge of the services performed on each research project (such as a department head or supervisor) for review and certification. h. Follow-up with their investigators for the timely return of certified effort reports. The Investigators are responsible for reviewing and certifying the effort certification forms in a timely manner. As part of their review, the Investigators will: a. Confirm all funds are listed and correct. b. Confirm salary charges are appropriate (percentages preprinted reflect salary distribution). Revised November 18, 2008 4 Research Management Operating Procedure 5. 6. Effort Certification c. Determine whether the time and effort listed on the reports reasonably reflects the time and effort expended on each organized research project and all other institutional activities (including patient care, instruction and teaching, and administration responsibilities). d. Make changes to the effort certification forms as necessary to accurately reflect the effort they committed on behalf of Partners during the relevant time period. e. Notify and work with their Administrators if changes are necessary. f. Work with their Administrators and the Partners Grant & Contracts Post-Awards Team to seek prior approval from federal sponsors for Significant Changes in Work Activity (i.e. if they expect to reduce their effort on any sponsored project by 25% or more, plan to withdraw from a sponsored project, or will be absent from Partners for more than three months (shorter period of time for some sponsors)). g. Certify their effort certification forms (sign & date). h. Return completed effort certifications to their Administrators. The Administrators will then: a. Review the effort certification, confirm the Total Professional Effort sums to 100%, and clarify any discrepancies if the effort certified is not consistent with effort committed. b. Make copies of the effort certification for their own records. c. Return the effort certification to the Partners Effort Certification Team by either: i. Emailing scanned copies to PHSeffort@partners.org (PDF preferred) or ii. Mailing original certified reports to Partners Research - Effort Reporting, 101 Huntington St., Suite 210, Boston, MA 02199 d. Effectuate any changes that may be required as a result of the effort certifications (See Partners Cost Transfers Policy) i. Assist with recertification of effort where needed (See Partners Effort Recertification Procedure) ii. Work with the Partners Grants & Contracts Post-Awards Team to seek prior approval from a federal sponsor if Significant Changes in Work Activity are anticipated for an Investigator (i.e. if they expect to reduce their effort on any sponsored project by 25% or more, plan to withdraw from a sponsored project, or will be absent from Partners for more than three months (shorter period of time for some sponsors)). The Partners Effort Certification Team will then: a. Collect effort certifications. b. Review for exemptions: i. Notations of T-32 or F32 trainees ii. Notations of non-research personnel iii. Notations of non-Partners compensated personnel c. Review for completeness: i. Signature and date received ii. Effort certified for each fund iii. Total Partners Professional Effort = 100% iv. Fund #’s and periods are valid for entry v. Status notations on sponsor approvals for Significant Changes in Activity d. Follow-up on any discrepancies. Revised November 18, 2008 5 Research Management Operating Procedure Effort Certification e. Enter certifications in their respective Effort Reporting database & mark returned. f. Retain effort certifications on file or electronic storage. Recertifying Effort Reports See Partners Effort Recertification Procedure Escalation Effort reporting compliance is maintained for each service by their corresponding department / division / center administrator. Should escalation be required, Administrators will follow their service’s escalation procedure for notifying their department chair / chief / director and research compliance officers. Process Flow Effort Certification Procedure – High Level Phases Report Generation Report Distribution Pre-review Review & Certification Certification Return Distribution Effort Certification Team Dept / Div / Ctr Administrators Investigators Dept / Div / Ctr Administrators Effort Certification Team Procedure Updated 10.27.08 Report Generation Report Distribution to Dept / Div / Ctr Administrators Pre-review by Dept / Div / Ctr Administrators Distribution of updated effort Reports to Investigators Review & Certification by Investigators Certification Processing & Filing Return of Effort Certifications to Dept / Div / Ctr Administrators Return of Effort Certifications to Partners Effort Certification Team Data Entry & Filing of Effort Certifications KEY Start End Revised November 18, 2008 6 Effort Certification Grants & Contracts Investigators Dept / Div / Ctr Administrators EC Team Research Management Operating Procedure Revised November 18, 2008 7 Research Management Operating Procedure Effort Certification Checklists/Tools:  Partners Effort Reporting Guidance (Q&A)  Partners Research Management Website Other Documentation:        Partners Effort Reporting Policy Partners Cost Sharing Policy Partners Cost Transfer Policy Partners Effort Recertification Procedure Partners Employee Data Changes Procedure 45 CFR Part 74, Section E – Hospital Cost Principles NIH Grants Policy Statement Revised November 18, 2008 8