Compliance

Under the oversight of the Office of Budget and Research Administration the Compliance program is based on our commitment to the effective management of sponsor support.  We assist the laboratories in their efforts to maximize research outcomes while adhering to Federal and other sponsor laws, regulations, and policy and we are committed to protect against fraud, misuse, or mismanagement of funds entrusted to our stewardship.  Our goal is to promote effective and efficient research administration practices as well as ensuring compliance with sponsor intent and requirements.

Effort Certification Policy Statement - As a condition of receiving sponsored awards, the University must assure sponsors that the effort expended on their sponsored projects justifies the salary charged to those projects.  The University maintains systems and procedures documenting the distribution of activity to individual sponsored agreements in compliance with federal regulations as defined by the Office of Management and Budget (OMB) Circular A-21.  All Principal Investigators (PIs) are required to certify their own effort. The effort certification of project staff may be delegated by the PI to another individual who has suitable means of verifying that the compensation paid and the effort expended are reasonable in relation to actual work performed.

Effort certification compliance requirement:

  • Effort Reporting - Concept, Terms, Frequently Asked Questions 
  • Effort Reporting - Roles and Responsibilities
  • Effort Reporting - Instructions for Key Personnel
  • Effort Reporting - Instructions for Other Personnel 
  • Effort Reporting - Sample Form 

    Sanctions for Non-compliance - Failure to follow the provisions of this effort reporting policy may subject the individuals and laboratories responsible for the violation(s) to administrative and/or disciplinary actions in accordance with University disciplinary procedures and the judgment of management.  Specifically, and without limitation:

    a) If effort reports are not completed and returned in a timely manner, salary costs associated with uncertififed grant activity may be removed and charged to a laboratory account.

    b) University administration may suspend submission of any new proposals on behalf of a noncompliant PI, or inclusion of a noncompliant researcher in proposals, until effort reports are up-to-date and properly completed and certified.

    c) Certification of effort reports that are known to be materially inaccurate may expose the individual who completed the reports to personal disciplinary action. 



    Cost Sharing Policy Statement - It is University policy not to allow cost sharing on federal sponsored agreements unless it is required by federal statute for that purpose and the sponsor approves the costs in writing.  Where cost sharing on federal sponsored agreements is allowed, all costs identified as cost sharing must be verifiable from the University's records, necessary and reasonable for the project or program objective, and allowable under the federal cost principles and administrative regulations set forth in the Code of Federal Regulations.  Cost sharing on non-federal awards is generally allowed subject to the same requirements for federal cost sharing, as well as the terms and conditions of the specific award.

    This office is located on the third floor of Founders Hall, Room 314B

    Dion Brown, Assistant Director of Budgeting
    Phone Number (212) 327-7976
    Fax Number: (212) 327-8533
    Email: Dion.Brown@rockefeller.edu