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Tufts University is required by federal regulations (2 CFR 200.430) to have a salary distribution system that allows for periodic review and confirmation of the reasonableness of salary charges to sponsored awards. At Tufts, quarterly effort reporting is used to verify that salaries and wages charged to a sponsored award for a specific period accurately reflect the time devoted to the project.

Exempt employees should understand how their salary charges are distributed and verify that their salary distribution reflects the actual effort devoted to the projects being charged. Central Post-Award is responsible for administering the University’s Effort Reporting System. Questions about the Effort Reporting System and procedures should be addressed to the Post-Award office on your campus.

Tufts University leaves of absence policy is outlined in the Employee Handbook. The employee’s department must work with the Leave of Absence Specialist to report the leave. If an employee is absent for more than 30 calendar days and the employee’s salary, or a portion of salary, is paid from a sponsored award, the salary may only be charged to the sponsored award for 30 calendar days or up to the date at which a replacement is hired for the person, whichever comes first; after which the salary of the person on leave must be  allocated to a department account. In cases when the sponsor agency issued guidance regarding the allowability of extended leave costs on the award, the sponsor rules will be followed.

Maximum Effort Threshold

Tufts University policy allows faculty members to charge up to 95% of their annual academic and/or supplemental/summer effort to sponsored awards if their other University responsibilities are less than or equal to 5% of their total time and effort. Non-sponsored activity includes responsibilities related to teaching, grant writing, committee participation, administrative duties, department or other chairmanships, or other administrative responsibilities. While committed sponsored effort is certified at the account level, the effort associated with non-sponsored activities is aggregated.

Recording Time and Effort Distribution

  • Exempt and professional staff time is charged to sponsored awards on the basis of information on the most recent Personnel Action Form (PAF). This establishes the initial distribution of effort which is certified on the Quarterly Effort Report (QER) or modified as necessary to present an accurate record of how the time charged is spent.
    • Prospective modifications of salary distribution should be made by Local Research Administrators (LRAs) via electronic Labor Distribution System.
    • Retroactive changes for salary distribution not yet reflected on a QER must be
      made via submission of a change PAF to Post-Award.
    • Changes to Full-Time Equivalent (FTE) or salary amount (both prospective and retroactive) must be submitted to Tufts Support Services (TSS) with a copy to Post-Award.
    • Changes may also be made to the employee’s distribution via the effort certification process described below. Adjustments should be annotated on the QER at the time of certification and returned to Post-Award by the due date specified on the QER Memo.
  • Non-exempt personnel report their effort on a weekly basis using the University’s Online Time Entry System. If a change impacting a sponsored award is required, a recertification request must be submitted to Post-Award.
Effort Certification Procedures

Tufts University uses an after-the-fact activity records approach to certify the effort of all salaries and wages paid from sponsored awards.

Effort for non-exempt employees, who are paid weekly, is certified when the Time Entry is submitted in the Online Time Entry System. Effort is certified on a pay period basis by the responsible person with suitable means for verifying the work performed. All hours entered should correctly reflect the time worked for the period noted and the salary distributions should represent an accurate accounting of effort expended.

Covered exempt employees (faculty and professionals) and graduate student employees are those whose effort is charged to sponsored awards, in part or in full. Covered employees certify their effort quarterly via the Quarterly Effort Reports (QERs) (sample).

Non-covered faculty/exempt personnel perform functions at the University are not subject to certification. An effort certification report is not produced for personnel whose effort is charged 100% to DeptIDs (non-sponsored accounts) however if changes are required, Non-Covered Reports will be provided upon request at the same time when QERs are produced. Please send your requests for Non-Covered Reports to postaward@tufts.edu before the end of each quarter.

Note: FTE & Salary changes cannot be done on a QER.

Distribution and signing of effort reports

QERs are sent electronically to the designated points of contact (QER POC) at each school or center. QERs for students whose effort is charged to sponsored awards are sent to the schools that own the student’s home DeptID with a copy to the department for the award(s) listed. Each school/center must update Post-Award in a timely fashion if their QER POC(s) change. Schools can have more than one QER POC.

QER POC distributes QERs to the individuals for signatures, follows up on their receipt, and submits them to postaward@tufts.edu.

The following process will apply to all QERs for covered employees, including those reflecting Joint Appointments.

  1. One month before QER distribution an e-mail confirmation is sent to the designated QER POCs confirming that the distribution is up-to-date.
  2. QERs will be saved as an individual PDF file with the naming convention: FY­­_Qrtr_HomeDeptID_LastName_FirstInitial
  3. E-mails by Post-Award will be sent to the QER POCs with the attachment of a Zip file containing the QERs for their Home DeptID.
  4. Once QERs are reviewed and signed by the appropriate parties, they should be returned to the designated QER POCs for each school or center for submission to postaward@tufts.edu.

QERs must be signed electronically using a digital signature that authenticates the signer (such as, for example eSignature or Adobe Sign). A scan of the original physical signature on a document is also acceptable. An electronic image of a signature does not provide the authentication of the signer and should not be used for the purposes of effort certification.

Individuals whose effort is charged to sponsored awards can either sign their QERs themselves, or the Principal Investigator (PI) can sign the QERs of individuals who worked on their award. The signature by the PI is strongly encouraged. Another person may sign only if the individual certifying the report has suitable means for verifying the expended effort. Suitable Means Checklist must be attached to QERs with proxy signatures.

When stipends are processed via compensation, Tufts system does not distinguish stipend payments from payroll disbursements resulting in QERs generated for the stipend. If you receive such a QER, please insert the following statement in its entirety on the bottom of the QER and return it to postaward@tufts.edu with the signature of the person who has direct knowledge of the approved stipend amount (such as, for example, a mentor or a Local Research Administrator).

This QER reflects a stipend and not a salary for [Name of the person listed on the QER], who is a trainee/fellow. There is no effort related to this stipend and it is not being received as a condition of employment.  The signature on this form confirms that the trainee/fellow is currently enrolled in a program, has an approved appointment, and that the associated stipend payment is accurate.

Please note that a stipend is provided as a subsistence allowance to help trainees/fellows defray living expenses during their research training experience. Stipends are not provided as a condition of employment, are not considered salaries, and do not have requirements surrounding effort.  Stipends must be paid in accordance with the stipend levels established by the NIH or other agency/sponsor as directed for the approved appointment period and should be pro-rated for early termination/completion as applicable.

Schedule

QERs are produced for the following quarters and must be returned to Post-Award ten business days after receipt. The due date for QER submission will be included in the Post-Award e-mail to the designated QER POC. Additional time should not be required, but if extenuating circumstances arise, an extension may be requested from your Post-Award Specialist.

QER Production Schedule

1st Quarter: July 1 – September 30QERs sent in early October
2nd Quarter: October 1 – December 31QERs sent in early January
3rd Quarter: January 1 – March 31QERs sent in early April
Mock (draft) QERs: April 1 – May 31 onlyMock QERs sent in early June
4th Quarter: April 1 – June 30QERs sent in early Jul

Note: Signed mock QERs have to be returned only if changes/adjustments are required. 

Effort Distribution Adjustments

In the event that changes are required to the effort already entered for non-exempt employees or to the effort certified on a QER in a prior quarter, a memo must be attached with the request with the following questions answered:

  • Why was the effort not charged to the correct project originally?
  • How does the expense directly benefit the receiving award?
    • Is the cost allowable, reasonable, allocable and consistently
      treated?
  • Why is the cost transfer over 90 days?
  • What corrective action has been taken to correct systematic problems?

For individuals paid entirely or partially from sponsored awards, all changes must be certified by the PI, employee, or other individual who has suitable means to verify the effort expended or work performed.

Please note that effort recertifications should occur only under very rare circumstances. Recertifications that involve moving salary onto a sponsored award are subject to additional scrutiny due to their high audit risk.