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Confirmation of Compensation for Personal Services Charged to Externally Sponsored Agreements – Effort Reporting Policy

West Virginia University Policy
Division of Administration and Finance


WVU-CO-3

CONFIRMATION OF COMPENSATION FOR PERSONAL SERVICES CHARGED TO EXTERNALLY SPONSORED AGREEMENTS – “EFFORT REPORTING” POLICY

PURPOSE

The purpose of this policy is to ensure that WVU shall adhere to and comply with Office of Management and Budget Circular A-21 regulations governing the confirmation of compensation for personal services that are either charged to or used as cost share/match for externally sponsored agreements.

SCOPE

This policy applies to all University employees, including those on the regional campuses.

POLICY

WVU shall adhere to and comply with Office of Management and Budget Circular A-21 regulations governing the confirmation of compensation for personal services that are either charged to or used as cost share/match for externally sponsored agreements.

“Direct cost activities and facilities and administrative cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or facilities and administrative cost activities if other responsible persons make appropriate confirmations.”

WVU maintains an after-the-fact activity report through the implementation of the Effort Reporting Certification System. As defined in OMB Circular A-21:

These “reports will reasonably reflect the activities for which employees are compensated by the institution. To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employees during the period, the reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed.”

PROCEDURE

Procedure development rests with the Assistant Controller of Sponsored Research and Cost Accounting of the Controller’s Office.

RESPONSIBILITY FOR IMPLEMENTATION

The responsibility for implementation of this policy rests with the Dean or Director of each college, department, or unit. The Controller’s Office, at 293-4002 or P.O. Box 6001, is available to answer questions or provide additional information regarding this policy.

RESPONSIBILITY FOR INTERPRETATION

The responsibility for interpretation of this policy rests with the Controller, West Virginia University.

Effective Date: September 10, 1998
Approved By: Scott C. Kelley, Vice President