Effort Certification After a Mid-Year Rebudget
A PI on a federally funded project is budgeted at 25% effort across the academic year. In month 5, the PI takes on a departmental administrative role and asks you to reduce charged effort to 10% for the remaining months while keeping the same total salary charged to the award. The department administrator proposes moving the difference to a 'cost share' line to avoid a budget modification. The sponsor requires prior approval for changes in key personnel effort exceeding 25% of the approved level and requires cost sharing to be documented and approved at proposal stage. The PI's committed cost share was zero. An effort certification for the prior period is due in three weeks.
1. Evaluate the proposed effort reduction and the cost-share workaround.
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Reducing the PI's charged effort from 25% to 10% is a change of more than 25% of the approved level and likely requires prior sponsor approval as a key personnel change. The PI cannot unilaterally reduce committed effort.
The cost-share workaround is improper. Cost sharing that was not committed at proposal and not approved cannot be manufactured mid-award to absorb salary. Charging salary to a cost-share line without an approved commitment misstates the award's financial record and may violate the sponsor's cost-sharing rules. If the institution voluntarily contributes effort, it must be documented under an approved voluntary committed cost-sharing arrangement, not invented to balance a budget.
Options: (1) request prior approval for the effort reduction with justification; (2) keep the PI at the committed level and adjust other duties; or (3) if the sponsor allows, rebudget within expanded authority and document the change. Do not certify effort that does not reflect actual work performed.
2. What must the effort certification reflect, and what are the consequences of certifying the original 25%?
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Effort certification must reflect the actual percentage of time spent on the award during the certification period, not the budgeted amount. If the PI actually worked 25% during the certification period, certifying 25% is correct even if future effort will drop. If the PI worked less, the certification must show the actual figure and the payroll must be adjusted.
Certifying 25% when actual effort was lower is a false certification. Consequences include disallowance of the unallowable salary, repayment, findings in a federal audit, damage to the institution's risk rating, and potential individual liability for the certifier. Certifiers must have personal knowledge or a suitable means of verifying the work.
Practical steps: gather contemporaneous records (timesheets, calendars, project deliverables), reconcile payroll to actual effort, process a cost transfer if needed with proper documentation, and ensure the certifier understands the certification is based on actual activity.