The United States Office of Management and Budget (OMB) has established cost principles for educational institutions. Costs for university projects with funding should comply with guidelines stated in the OMB Circular A-21
Effort reporting- OMB Circular A-21
“Plan Confirmation” system. The PNF is the “Plan”, and the FTE Certification is the “Confirmation of the ‘Plan’”.
The percentage on PNF equals the percentage promised on the award budget. Deviations deserve follow-up.
Effort reporting is required. FTE Certification is the primary supporting document and compliance is essential.
Effort Reporting- FTE Certifications
You will be working with ITS on security issues such as SSN#.
Due dates for Sep., Dec., March, and June. Certifications are 45 days from the “report available date”.
Completing the certification involves printing the document from Page Center, preparing applicable annotations, and obtaining required PI and FO signatures.
The PI’s signature represents a certification that the effort % of individuals is “allocable” and “reasonable”.
If PI is unavailable to certify, you need to make sure that another individual has been delegated this responsibility and this PI designee must have first hand knowledge of the project work “with suitable means of verification that the work was performed.”
The FO’s signature is to certify that annotations have been made.
New annotations or changes require new sets of signatures. Do not alter or delete prior annotations or signatures.
ORS monitors and reports timeliness to BOR and VPs. You should be concerned if there is a repeated non-compliance audit finding. This process is very important and there are severe consequences for non-compliance.
Settlements for allegations of working fewer hours than reported and overstated effort (whistleblower) have been in excess of $3.3 million.