Time and Effort Reporting

Policy statement and procedures Adopted August 2008

Policy Statement

The University will follow the restrictions and requirements of Office of Management and Budget (OMB)’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, known as the Uniform Guidance, as well as other applicable federal regulations with respect to certifying effort charged to federally sponsored projects. The University will maintain an effort reporting system and obtain effort certification from employees in compliance with federal regulation. The University requires employees to certify the accuracy of the percentage of time (i.e., effort) charged to sponsored projects. If effort is not properly certified, salary charges must be removed from the sponsored account.

Reason for Policy

Effort reporting is a federal requirement. The government requires that institutions receiving federal funds for sponsored agreements maintain an effort certification process that complies with the requirements set forth in Uniform Guidance Subpart E §200.430. Section §200.430(c) states, “It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs [Institutions of Higher Education] a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”

Furthermore, federal and state agencies, private foundations, organizations and industry provide significant funding to enable the University to conduct research, public service and training projects. The University’s effort reporting system assures these external sponsors that funds for the projects they sponsor are properly expended by certifying that the salaries and wages charged to the projects are consistent with the effort contributed. All employees involved in certifying effort must understand that severe penalties and funding disallowances could result from inaccurate, incomplete or untimely effort reporting.

Finally, sponsors and auditors must be able to verify that funds allocated for cost sharing have been provided. The effort reporting system is the mechanism the University uses to document cost-shared salary expenses.

Procedures

The effort certification report accounts for 100 percent of all effort for which the University compensates the individual. Even where the number of hours of effort the individual expends each week substantially differs from the “normal” workweek of 40 hours, effort percentages are based on total effort, not hours.

The University effort certification reports are to be signed by the employee, the principal investigator or other responsible official to confirm that all activities (sponsored and nonsponsored) are reported correctly and that the distribution of effort shown on the certification report reasonably reflects the percentage of total effort that was spent on each activity.

Frequency

Gallaudet has three reporting periods, which follow the University’s academic calendar: fall, spring and summer. Approximately 90 days after the end of each semester, the University will generate effort certification reports, which must be completed and returned within the defined deadline.

Distribution and Certification

Every principal investigator (PI) will receive a packet of reports-one report for each person who is compensated in whole or in part by the PI’s sponsored research project. The report will show the employee’s projected effort distribution as of the end of that semester. The PI will be responsible for the following:

• Reviewing the preprinted effort report percentages and comparing them to the committed level of effort in the authorized budget.
• Distributing the report and obtaining the employee’s certification. Signing the report confirms that effort, as certified, reasonably represents the effort expended during the period. If employee(s) are unavailable to certify their time, then either the PI or another responsible official may sign the report(s), if he/she has suitable knowledge of the employee’s effort.
• Retaining a copy of each employee’s report.
• Returning the original reports to the Finance Office within the defined deadline.

If the effort reports are not properly certified and returned to the Finance Office in the requested timeframe, the salary charges will be transferred from the sponsored grant account back to each employee’s home department.

Corrections

Actual effort should be closely monitored throughout the life cycle of each award. Significant changes to planned effort distributions should be made as soon as they are known. If, at the end of a certification period, the effort percentage reflected on the certification is not a reasonable estimate of the employee’s actual effort, the percentage should be crossed out in ink with the correct percentage written in the margin.

A Personnel Actions (PAF) may be required with a corrected certification report. In accordance with the Cost Transfers Policy, correcting forms should be completed, signed by the appropriate personnel and sent to the Finance Office for processing and approval. The Finance Office will review each cost transfer to ensure the transfers and related explanations meet the budget, allowability and allocability requirements.

With effort certification, special consideration must be given to the timeliness of payroll cost transfers. University policy requires that the payroll distribution match the effort percentages certified on the effort certification report. Payroll cost transfers, accompanied by appropriate explanations, are strongly encouraged prior to the certification of effort. In the rare instance it is necessary to process a payroll cost transfer to correct a report that has already been certified, the request must include a written justification. The historical salary adjustment should be submitted within 180 days of the period being certified, and it must be approved and signed by the University controller.

Cost sharing describes the portion of a sponsored project’s cost that is borne by the University rather than by the external sponsor. One example of cost sharing is where some or all of an individual’s effort is expended on a specific sponsored project, as a requirement of the award, but not funded by the external sponsor. Another example would be where a portion of the compensation for an individual’s effort exceeds a salary cap imposed by the sponsor, such as the National Institutes of Health. The effort not supported by the sponsor should be reported as cost sharing. It appears on the effort certification report as a department number description beginning with “CS.” Any cost-sharing time should be checked for accuracy as part of the review of the overall effort identified in the certification report.

Forms/Instructions

• None

Related Information and Resources

External Resources

• NIH Salary Limitation on Grants, Cooperative Agreements, and Contracts

Internal Information

• Cost Transfers Policy

Definitions

Responsibilities

History

Origination date: August 2008 Last amended date: May 2020Next review date: