Cornell
University Policy Library -- Policy 3.11ENTITIES AFFECTED BY THIS POLICY
Cornell University requires effort planning and confirmation for certain operating units.
The university receives significant funding for sponsored projects from federal and state governments, private foundations, organizations, and industry. There must be accurate effort planning and confirmation when these funds are expended for the salaries and wages of faculty and staff. In addition the Contract Colleges have special New York State effort reporting requirements.
All units of the university, excluding the Weill Cornell Medical College and Graduate School of Medical Sciences
- Administrators and Department Managers
- Deans, Directors, and Department Heads
- Grant and Contract Officers
- Principal Investigators
- Staff members working on sponsored projects
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University Policies |
Other Documents |
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University Policy 1.1, Cost-sharing University Policy 2.6, Reporting the Use of Facilities University Policy 3.7, Accounting: System Structure and Transactions University Policy 3.20, Cost Transfers on Sponsored Projects |
Cornell University Cost Accounting Standards Disclosure Statement (DS-2) Faculty Handbook Office of Sponsored Programs Costing Guide Office of Management and Budget (OMB) Circular A-21: Cost Principles for Educational Institutions Office of Management and Budget (OMB) Circular A-110: Uniform Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations |
Direct any questions about University Policy 3.11, Effort Planning and Confirmation, to your Unit Administrator or your unit’s administrative office. If you have questions about specific issues, call the following offices:
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Subject |
Contact |
Telephone |
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Clarification on Specific Awards |
Sponsored Program Services - Agreements |
(607) 255-5014 |
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Documentation for Plan Confirmation |
(607) 255-5657 |
uco-cost@cornell.edu | |
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Grants and Contracts Accounting |
(607) 255-5085 |
uco-sfa@cornell.edu | |
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Labor Distribution |
(607) 255-9472 |
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Award |
An executed agreement between Cornell University and a sponsor. |
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Confirmation |
Verification. |
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Cost-sharing |
A portion of total project or program costs related to a sponsored agreement that is contributed to a sponsored project or program by someone other than the primary sponsor. |
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Effort |
Activities related to a Principal Investigator's or employee's duties, for which university compensation is received. External activities such as consulting are not included. |
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Effort Distribution |
An allocation of one's time to various activities. |
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Function Code |
A three-digit numeric account attribute that indicates the specific purpose or use of the funds contained in an account (i.e., research or instruction). |
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Labor Distribution |
An allocation of one's efforts to specific general ledger accounts. The general ledger documents effort in the university's books and records. Note: Labor distribution requires a conversion of time (i.e., effort) to dollars (i.e., compensation). |
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Plan |
A projection of future activities. |
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Plan Confirmation |
A system of documentation that includes: (a) an effort plan (i.e., budgeted, planned, or assigned work activity, updated to reflect any significant changes in work distribution), and (b) effort confirmation, whereby at least annually a statement will be signed by the employee, Principal Investigator, a responsible official(s), using suitable means of verification. This statement must state that the work was performed, and that salaries and wages charged are reasonable in relation to the work performed. |
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Sponsored Project |
A project funded by a grant, contract, or cooperative agreement under which the university agrees to perform a certain scope of work, according to specified terms and conditions, for a specific budgeted monetary compensation. |
The Office of Management and Budget (OMB) Circular A-21 Cost Principles for Educational Institutions includes regulatory requirements for the planning, confirmation, and certification of effort associated with Federal organized research projects and other activities. Effort directly charged to sponsored projects, cost sharing, and any other statutory-funded activities must be identified in the university's effort distribution/reporting system.
Note: For the endowed colleges, these procedures must be followed for individuals with sponsored activity during the fiscal year. For the statutory colleges, these procedures must be followed for all individuals.
This policy rescinds and supersedes prior university policies and procedures governing effort planning and confirmation.
There are two basic rules to understand before reading further into this policy.
1. The effort planning and confirmation system must only reflect the activity for which the investigator or employee is compensated by Cornell. External activities such as consulting or non-university (professional) committees are not to be included.
2. We are required to record effort as a percentage of total activities, not as hours worked. Therefore, all of an employee's compensated activities equal 100% of Cornell effort regardless of whether they are accomplished in 20, 40 or 80 hours per week, and regardless of the appointment FTE.
There are several acceptable methods of reporting described in the OMB Circular. Cornell uses what is referred to as a "Plan Confirmation" method. This effort distribution reporting is normally accomplished by the department or unit administrative manager, in consultation with the Principal Investigator as necessary. This means that at the beginning of each fiscal year salaries and wages are planned and distributed to various activities based upon the individual's expected effort. The effort distribution must be adjusted in a timely fashion for any significant (more than 10%) changes in effort when they become known.
1. Develop an effort plan for each individual before the end of May, each fiscal year.
2. Periodically, review effort distribution for appropriateness and accuracy of effort expended on all projects. It is recommended that the review be done monthly.
3. Complete an Account Distribution and Adjustment Change Form and submit a copy with confirmation, for retroactive or prospective adjustments (see the "Forms").
4. Verify and sign a plan confirmation statement, at least annually, using suitable means of verification that activities identified in the University Labor Distribution system are reasonable in relation to work performed. Use the Accounting Function Codes listed in Table 1.
Table 1
Effort Categories
Instruction & Departmental Research
Organized Research
Extension and Public Service
Accounting Function Codes
41X
43X
44X
Sample Activities
Administrative Activities
Advising
Committee Work
Curriculum development
Departmental Research
Hiring and Supervising
Instruction Training Grants
Proposal Preparation
Supervision of TA’s
Teaching (credit/non)
Research Projects
Research Training Grants
Statutory Only*
*Departmental Administration (Statutory Project Code 597)
*Research Support (Statutory Project Codes 595, 596, 598, 599)
Community Service
Extension Projects
Statutory Only*
*Departmental Administration (Statutory Project Code 697)
*Extension Support (Statutory Project Codes 695, 696, 698, 699)
Note: OMB defines "Organized Research" as all research and development that is separately budgeted and accounted for. The classification of Organized Research (function code 430) should include only the effort spent on research, whether it is paid by the sponsor or Cornell, not proposal writing or administrative functions connected with that organized research project, such as other management or supervisory effort connected with recruiting faculty or administrative staff.
Note: See University Policy 3.7, Accounting: System Structure and Transactions for more information on accounting function codes.
At least once each year the actual effort of the employee must be reviewed and confirmed by someone with first-hand knowledge of the effort. Effort should be reviewed and confirmed at the same time the plan for the next year is established. The table below outlines the steps that must be taken.
Table 2
Plan Confirmation Procedures
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Who |
What |
When |
Description |
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1 |
Cost and Capital Assets |
Mail Plan Confirmation Worksheet Report |
After May month end each fiscal year |
Reports include year-to-date activity for all individuals who had sponsored activity during the fiscal year (in the statutory colleges: for all individuals). |
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2 |
Unit Administrator |
Verify that employees received required statements to confirm |
by established deadlines |
If individuals working on sponsored activity do not receive a report notify Cost and Capital Assets immediately. Review Report 189, Account Distribution and Adjustment. |
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3 |
Principal Investigator/Unit Administrator |
Review Plan Confirmation Worksheet |
Prior to payroll year end cut-off |
Confirm that all activities are reported. Review Cost Sharing requirements. Verify effort amounts are correct. |
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4 |
Principal Investigator/Unit Administrator |
Make any adjustments to Actual (for current fiscal year) or Plan (for next fiscal year) |
Prior to payroll year end cut-off |
Cross out the percentage on the plan confirmation form and indicate actual or planned effort. Complete an Account Distribution and Adjustment Change Form and submit a copy with confirmation, for retroactive or prospective adjustments (see the "Forms"). |
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5 |
Principal Investigator/Employee or someone with first hand knowledge |
Certify Plan Confirmation Worksheet Report |
Prior to payroll year end cut-off |
Individuals having direct knowledge of employee’s total effort can confirm statement (preferably the employee). Return the corrected report and copies of any adjusted entries to Cost and Capital Assets, Division of Financial Affairs, 341 Pine Tree Road. |
The major responsibilities each party has in connection with this policy, are as follows:
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Department Head |
Establish effective processes and controls to ensure compliance with this policy. Ensure accurate planning and confirmation of effort, including cost-sharing. Assume responsibility for or assign an administrator to oversee the effort planning and confirmation process. |
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Principal Investigator/ Employee/ Unit Administrator |
Ensure appropriateness and accuracy of all effort expended on sponsored projects. Provide updates to effort distribution system, as changes become known. Certify plan confirmation with first-hand knowledge. |
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Cost and Capital Assets |
Develop and implement plan confirmation procedures in accordance with regulations set forth in OMB Circular A-21, "Cost Principles for Educational Institutions." Develop and provide appropriate training to all employees involved in the effort planning and confirmation process. Produce effort statements for all employees identified as expending effort on sponsored projects or in statutory colleges. Monitor the effort planning and confirmation process to ensure compliance with this policy. Check for timely submissions, accuracy, and completeness of plan confirmation statements and report findings to departments. Report questionable practices and recurring problems to Deans, Department Heads, and the University Audit Office. |
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Form |
URL |
| Account Distribution and Adjustment Form | http://www.policy.cornell.edu/finance_forms.cfm |
Sample Plan Confirmation Worksheet
