This effort reporting policy was developed in accordance with the Office of Management and Budget (OMB) Circular A-21, which addresses “principles for determining costs applicable to grants, contracts, and other agreements with educational institutions.”
The following procedure describes the process that the University follows to comply with these federal requirements. It is critical that the institution follow this procedure as failure to comply with A-21 can have serious consequences for the relevant project, department, and the institution as a whole. Adverse findings by auditors can result in fines, reimbursement to the government, and termination of funding.
Although actual effort will inevitably vary from pay period to pay period, the amount charged to sponsored projects should reflect the average of time worked throughout each academic term. Effort certification is the endorsement by an employee (or another knowledgeable party) with suitable means of verification that the labor charges incurred and reported in the effort report reasonably reflect the effort expended during the time period being reported.
An effort report (ER) is created to account for all components of University and/or Foundation paid salary. The report includes a certification statement that reports the breakdown of contribution of effort into four categories (Instruction and Other Non-sponsored Time, Cost Sharing, Sponsored Project Reimbursed Time and Additional Employment Time) on a 100% basis. For example, a faculty member who is paid 100% of his or her base salary from the University for Instruction and Other Activities and an additional 25% of their base salary for participation on Research Grant “A” would receive an effort certification statement displaying 80% effort in the Instruction and Other category and 20% effort devoted to Research Grant “A”.
The Office of Research and Sponsored Programs (ORSP) will be responsible for gathering and entering the appropriate information into the employee’s effort report spreadsheet in order to create accurate effort certification reports. ORSP will produce these effort certification reports twice per fiscal year for the following periods: July through December and January through June.
All employees with effort devoted to a sponsored project (paid directly or cost shared) will be required to certify their effort reports for the six months in which they performed that effort. A project director or responsible official with direct knowledge of an employee’s effort may sign if the employee is not available to sign.
Effort for Foundation hourly-paid employees is certified each pay period on their time card. For exempt Foundation staff, a Salaried Employee Effort & Absence Report is submitted each pay period which shows the percentage of effort spent on each project. The Foundation Payroll staff compares the level of effort on the report with the salary distribution each pay period. Inconsistencies are reported to the GCA for resolution.
Components of Effort Certification Statements
The effort report divides each employee’s effort into two sections: University Compensated Effort and Foundation Compensated Effort. The University Compensated portion of the statement is broken down into three categories: 1) Instruction, Departmental Research, and Other Non-sponsored Activities (UA); 2) Reimbursed Time (RT); 3) Assigned Time/Cost Sharing (CS). The Foundation Compensated portion has the last category titled Additional Employment (AE).
Effort Reports reflect a university employee’s entire compensation both by the university and the Foundation as 100% of an employee’s effort.
Distribution of Effort
The ER takes the effort paid for each of the categories and divides by total effort paid (including Additional Employment) to compute the percentage of effort on a 100% basis.
Effort Certification Timeline for Distribution and Return of Reports
Effort reports are prepared and certified twice per year. The report preparation and certification period is no later than 5 months after the reporting period ends; January – June, report cycle completed in November; July – December, report cycle completed in May.
3) Roles and Responsibilities
- Develop and maintain the Effort Reporting System and all related policies and procedures
- Provide adequate education and training about the effort certification process to the affected employees on campus.
- Distribute all Faculty Reimbursed Payroll (Blue) forms that involve sponsored project accounts to the GCAs for allowability approval.
- ORSP personnel will gather the appropriate information, as described in Section 2.B “Components of Effort Certification Statements.” The ERs are prepared 2 – 3 months following the end of each academic term after the monthly faculty payroll is posted for the month following the end of the academic term.
- ORSP will review each of the Employee Effort Reports every academic term for accuracy.
- Distribute each of the ERs to the appropriate employees.
- Monitor which statements have not been returned and follow up with those individuals according to the established timeline.
- Provide University salary and appointment information for all University employees, upon request of ORSP.
- Understand the Effort Reporting process and requesting training from ORSP if desired.
- Ensure that he or she and all employees working on his or her sponsored agreement are being charged with reasonable accuracy and that any changes to effort charges are made timely. Also, ensure that they and the employees working on a sponsored project are completing the effort certification reports in accordance with the established timeline and federal requirements.
Administrative Services Manager
- Provide assistance to the Project Director and ORSP as needed to ensure that all salaries, wages, and fringe benefits are being charged accurately to sponsored agreements.
Dean/Associate Dean/College URAC Representative
- Assist the ORSP in the case where a PI is not compliant with accurate completion of the effort reporting process for the employees working on his or her project.
- OMB Circular A-21, Section J (10)
- OMB Circular A-110