Past certification period PAAs exemption request process begins September 3

If a PAA is first submitted into Workday without an exemption approval, it will be sent back to the initiator. Once an exemption is submitted, it will be reviewed, and, if approved, initiators  will receive a notification to enter the request in Workday.  

These policy exceptions will be tracked by investigator, department and college and will not be unlimited. Beginning in December 2024, exceptions (PAAs for already certified effort or for effort from prior certification periods) will rarely be approved and only in specific circumstances such as late award issuance or sponsor request.

In order to be compliant with policy for recipients of federal funding, errors or omissions to staff appointments and any correcting PAAs should be submitted within 90 days of the beginning of the pay period. Additionally, incorrect or incomplete effort should not be certified; limited exceptions will be allowed during this period. Adjustments later than 90 days should be rare and not a method of managing awards and budgets.  

Want to know more about why time and effort is important? 

Funders ask investigators for a reasonable budget as part of the award application and, once approved, expect that the project be expensed accordingly. After work has begun, researchers are asked to confirm that the effort charges for a period are correct and complete through effort certification. 

Certification reports are generated at the end of each reporting period (three times per year at Ohio State), when Workday collects all payroll information for each employee, which is then used to compute the percentage of salary charged to each funding source. PIs certify effort for themselves and their postdocs, students and biweekly employees. Co-investigators and other professional staff certify their own reports. 

• If the report is correct and complete, the certifier approves. Effort percentages are imprecise and granting agencies consider certified levels of effort within +/- 25% of that committed to be acceptable. 
• If a report is incorrect, it should not be signed and steps should be taken immediately to initiate a correction in Workday through a PAA. When ready, the researcher will be alerted that a corrected effort report is available for certification. 

Effort reporting practices to avoid

Trying to spend a grant down to $0 is not recommended. Under the uniform guidance, charges must “reasonably reflect” what took place – small over- or under-runs are to be expected, given changes in fringe benefit rates over time and other cost differences from the time of proposal. Thus, researchers should avoid:

• Overly precise requests, such as changing an appointment by 17.345% for one month.
• Moving effort from one sponsored award to another because the second was not yet in place. 

Regular grant maintenance saves time and reduces risk

• The complexity of research administration underscores the need to monitor projects and make personnel changes frequently and on a regular cadence. Awards can be monitored through the PI Portal or Workday Grants Reporting.  
• Late corrections can mostly be prevented by frequent, regular grant reconciliation. Including updating appointments monthly. Effort in particular is heavily scrutinized by sponsors and auditors as it makes up the highest percentage of charges to sponsored projects. Sponsors view retroactive corrections to effort charges after certification as an indication of poor award management. Penalties for violations or findings of weak institutional controls can be significant.