The University of Pittsburgh Effort Reporting policy provides that Principal Investigators (PI) are responsible for certifying effort statements for themselves and all employees working on their federally sponsored projects. A Proxy or Designee is a person who has been authorized to certify on a PI’s behalf. To be approved, the Proxy/Designee must demonstrate that he/she meets the prescribed standards for certification; a responsible University official with direct first-hand knowledge of the volume and nature of the technical work performed, or an individual with "other suitable means of verification" of the effort distribution.
There are instances where the PI of a federal award may not be able to certify effort on their own award, such as:
- Terminating from the University
- Grave illness
- An Unallowable Job Classification
While Proxy and Designee assignments require the same level of knowledge/verification of the work performed on federally sponsored projects, they differ as follows:
- A Proxy will be able to certify the PI’s personal effort statement only. The Proxy relationship is a person to person delegation.
- A Designee will be able to certify the effort of all employees working on a specific federal project, except the PI of this award (see Proxy) or any other federal PI working on this award (PIs certify 100% of their own effort). The Designee relationship is a person to project delegation.
Requests to create these roles require the approval of the CFO or his designee. Please refer to Appendix I, Proxy/Designee Decision Tree for assistance in determining which role is appropriate.
As soon as it becomes clear that a PI will be unable to complete the electronic certification in ECC, the Effort Coordinator should determine:
- Which certifier role(s) is required. Please refer to Appendix I, Proxy/Designee Decision Tree for assistance in determining which roles are necessary.
- What academic period(s) will require delegation of certification responsibilities. For example, if the PI is leaving the University and will have effort beyond the current period being certified, please indicate the final period on the request and attach signed SPAR Certification Templates/PDF effort statements for all periods covered by the Proxy/Designee requests.
- What documentation is necessary to support all related effort statements. Refer to What constitutes documentation of ‘Other Suitable Means’ of Verification? below to determine which forms are appropriate.
If the PI is leaving the University, this should be accomplished prior to the PI’s departure.
Proxy/Designee requests may be submitted by either the PI’s home department or the grant department. In accordance with University’s Effort Reporting and Certification policy, the grant department bears the risk of write-off in the event that the effort remains uncertified. Therefore, it is imperative that the Proxy and/or Designee requests are submitted timely.
Determine who is most suitable to serve as the delegate based on their knowledge of the technical nature and amount of work performed on each federal project. Provide written justification indicating:
- why the PI is unable or unsuitable to certify and
- why the Proxy/Designee was selected to be the delegate, detailing his/her knowledge of the work performed.
Different faculty members may be selected to certify as Proxy or Designee for the same PI, depending on their experience with the specific federal projects. Fiscal Administrators will not be approved as certifier delegates.
The selected certifier delegates would optimally have direct, first-hand knowledge of the technical nature and volume of work performed for the related federal projects. First-hand knowledge means that the individual was present and witnessed or assisted in the work performed. Therefore, this person would also show some level of effort on the award.
If there is no appropriate delegate with direct first-hand knowledge of the work performed, the certifier delegate will need to possess “other suitable means of verification” of the work performed. The preferred method is to have the PI sign updated PDFs of effort statements or SPAR forms that the delegate can use for comparison to the electronic statements that he/she will be asked to certify. All SPAR modifications must be completed and updated in ECC prior to printing for PI signature to ensure agreement with the final effort statement. This documentation must be submitted with the request and a copy of each document retained by the Proxy and/or Designee for their use in comparing to the electronic effort statement(s) they will now be responsible for certifying. These documents should be retained by the Proxy/Designee for their audit records.
The timing of the preparation of this documentation will dictate which form (the effort statement or the SPAR) is used. Following are guidelines to determine which individuals require this documentation and which of the forms to use.
Identification of All Individuals for Which Documentation is Required
- From the ECC Reports menu, Payroll/Cost Share category, select Certifier Salary Activity Report (see screen shots in Appendix II)
- Enter Parameters as follows:
- PI – enter the PI name or employee number
- Statement Type – Base
- Date By – Dates
- Dates – Enter first day of the first month of the academic period requiring certification and the last day of the month 12 months later.
- The report will list all individuals with effort on any of the PI’s federal awards during the month entered or any month subsequent to that month for a 12-month period. The report provides detail of each individual’s payroll distribution for the period and highlights in gold those distributions to federal projects of the PI named in step 2a.
- You will want to ensure that you prepare a separate Designee Request form for each sponsored project included on the gold lines of the report. Attach a copy of this report to each Designee request.
- You will need to provide a copy of the signed effort statement PDF or SPAR Certification template for each individual with distributions highlighted in gold in the academic period to be certified.
- If gold highlighted distributions are present in the early months of the next academic period prior to the PI’s departure, documentation in the form of a SPAR Certification Template is also required for those individuals for that academic period.
- Keep in mind, $0.00 distributions on the Certified Salary Activity Report may represent a net balance of initial salary distribution and a subsequent SPAR modification to reverse the effort/salary charge. If this is the case, a 0% effort line may appear on the effort statement and require certification. You will need to consider this possibility as you identify accounts requiring Designees and employees requiring signed PDF effort statements or SPAR Certification Templates.
Determination of Effort Statement PDF vs. SPAR Certification Template – PI’s Personal Statement
For terminating PI’s, if his/her final payroll has been paid and reflected in ECC and all SPAR modifications have been made, print a PDF of the effort statement (as directed in Appendix III) and have the PI sign the accompanying attestation statement.
If PI’s final payroll date is still in the future, review the SPAR to ascertain if the future month’s payroll will modify the statement’s effort distribution as follows. The effort distribution will change if the percentages on the SPAR vary from month to month and when the amount paid varies. So, if effort percentages are not consistent across all four months of the SPAR period, the PI’s final pay will result in changes on the effort statement. In this case, paste a screenshot of the SPAR on the Certification Template shown in Appendix IV and found on FCR Forms page. Have the PI sign and date the attestation statement. Be sure to include all SPAR lines, additional sheets may be necessary.
If the SPAR percentages are consistent across all four months of the SPAR, the effort statement percentages will not change with the final pay. Print a PDF of the effort statement (as directed in Appendix III) and have the PI sign the accompanying attestation statement.
Determination of Effort Statement PDF vs. SPAR Certification Template – Research Employee Statements
For all research employees identified in the Identification of All Individuals for Which Documentation is Required section above, if the named PI is relinquishing certification responsibility as of the end of an academic period and the final payroll for the period has been distributed and reflected in ECC, and all SPAR modifications have been made, print PDFs of the effort statement(s) (as directed in Appendix III) and have the PI sign the accompanying attestation statement(s) for each.
If the PI is relinquishing certification responsibility at some interim point in the academic period, it is likely that duties and distributions for these employees may change over the balance of the period, affecting effort statement percentages. In this case, for the employees identified in step 5 above, ensure that all necessary SPAR modifications affecting the months prior to the PI’s departure are complete, then paste a screenshot of the SPAR on the Certification Template shown in Appendix IV and found on the FCR Forms page. Have the PI sign and date the attestation statement(s) accompanying each. Be sure to include all SPAR lines, additional sheets may be necessary.
For all research employees identified in step 6 of the Identification of All Individuals for Which Documentation is Required section above, because the academic period has not ended, it is likely that duties and distributions may change. For these people for this partial academic period, ensure that all necessary SPAR modifications affecting the months prior to the PI’s departure are complete, then paste a screenshot of the SPAR on the Certification Template shown in Appendix IV and found on the FCR Forms page. Have the PI sign and date the attestation statement(s) accompanying each. Be sure to include all SPAR lines, additional sheets may be necessary.
Requests should be submitted as soon as the need for a Proxy or Designee is realized. Unless otherwise indicated, the certifier delegate role is approved for one certification period; it will expire on the certification deadline of the period of performance for which application is made. If certification will be required beyond the initial period of performance, it should be explained in the request’s justification section with all required supporting documents for the subsequent period of performance included in the submission. If work is to continue at the University on any of the PI’s federal projects, a new PI will need to be approved by the sponsor and updated in RPA through the Office of Research.
Please submit each completed request as follows:
- Complete the first page of request providing all required information and signatures. Dean approval is not required on forms submitted by Department of Medicine divisions, Chair/Division Chief approval is sufficient.
- Complete the Justification Documentation (page 2 of form). Request must include a complete explanation for why the PI is not able to certify and why the individual selected to serve as Proxy/Designee is the best choice to certify the corresponding effort. If the Proxy/Designee has first-hand knowledge (meaning was on-site witnessing or assisting in the actual work) explain the relationship in detail. If the Designee does have first-hand knowledge of the work performed, it is expected that his/her effort distribution would include effort for the project in question.
- If no one has first-hand knowledge, then other suitable means of verification is required. Attach signed PDFs of all effort statements or SPAR Certification Templates signed by the PI. See What Constitutes Documentation of ‘Other Suitable Means’ of Verification above for determining which forms are best. Be certain to retain copies of the signed documentation for the Proxy/Designee to compare with electronic statements when certifying.
- A copy of the Certifier Salary Activity Report as prepared in What Constitutes Documentation of ‘Other Suitable Means’ of Verification, step 2 above, is required for all Designee requests.
Email the completed request forms and all supporting documentation to SPARhelp@cfo.pitt.edu for consideration. Enter the PI name and “Proxy/Designee Request” in the subject line (e.g. Jane Doe-Proxy Request).
- Please ensure that for either method described above that the screenshot is legible. The Snipping Tool available as an accessory in many Windows applications works well for this purpose.
- If your request is returned for any reason (e.g. missing signatures, insufficient justification or supporting documentation, etc.), please resubmit the entire request package. Piecemeal submissions will not be accepted.
- Keep in mind that the uncertified effort may cross over two periods of performance. For example, if a PI leaves the University in June, they will need a Proxy and/or Designee(s) set up for both the January – April period and the May – August period.
- Please note that SPAR modifications affecting federal sponsored projects after the above effort statements/SPARs have been signed will negate the Proxy/Designee’s means of verification. Proxies and Designees should not certify statements that do not agree with their signed documents from the PI. If a subsequent SPAR modification is absolutely necessary, please generate new supporting documentation and have them signed by the PI. Provide copies to the Proxy/Designee(s) and to SPARhelp@cfo.pitt.edu.
The Proxy and Designee Certifiers assume responsibility for electronically certifying the effort for the PI and/or all individuals working on specific federally sponsored project(s). They are personally attesting to the reasonableness of salary charges on the sponsored account(s) in relation to the work performed thereon. If the Proxy/Designee does not have first-hand knowledge (meaning was on-site witnessing or assisting in the actual work) of the work performed, they will compare signed documentation provided by the PI to the electronic statement to validate their certification. This documentation provided by the PI must be retained by the Proxy/Designee for audit purposes.
Below, the lines highlighted in gold are the lines that PI Time Karoli is responsible for certifying.
Karoli would need a Proxy to certify his own effort. He will also need a Designee for Project #130056 and a Designee for Project #130036 to certify effort for Kari Ting and Molly Hanada.
The green arrow above indicates the location of the icon used to create a PDF version of the effort statement for the PI’s signature.