Effort Certification & Reporting
A Quick Introduction to Effort Reporting
The federal government requires an effort report when an individual is compensated by or has agreed to contribute time to a federally sponsored project. Anyone who is paid by funds from a sponsored project is personally responsible for certifying the amount of effort that they have devoted to the project.
This overview provides a guide to effort reporting, including an explanation of why such a process is necessary and the requirements for compliance.
What is “effort”?
When you apply for a grant you indicate what percentage of your total work effort will be devoted to that particular project. Generally, note is made of this in the budget justification. The sum total of the effort you expend on that project and all the other institutional work you do (teaching, research, service) cannot exceed 100%.
In fact, normally the total effort you commit to expend on any one funded project is less than 100% because even if you have releases from all your courses, you will still be spending some portion of your effort on advising, faculty meetings, and the like. Only during the two months in the summer, when the funded project can truly be said to be consuming all your effort, can you report a full 100%.
Note: effort is calculated in relation to your Institutional Base Salary which does not typically include outside consulting --- only what's paid for by the institution. Thus, if you have a consulting job outside the University, that work is not counted as part of effort because it is not carried out in your capacity as a University employee.
Don’t confuse effort with time. If you only work one day a week and spend half of that day on the project your effort is 50%. If you work 40 hrs and spend half that working on the project your effort is still 50%. Even when the number of hours of effort exceeds a normal work week, the total effort cannot exceed 100%. If you work 120 hours per week and half of that time is on the project your effort is still 50%.
What is an “effort report?”
Unlike attendance records that indicate that a particular employee was present for duty or out for vacation or sickness, etc; effort reports indicate what particular project the employee was working on for what proportion of his or her effort.
The federal government requires that the University verify that the effort compensated by a sponsored project has actually been performed. (Did you do as much work on this project as you were paid for?) These regulations are outlined in OMB Circular A-21.
When a project is funded, the Principal Investigator (PI) submits the percentages of effort that employees are expected to expend on the project to the Office of Sponsored Programs (OSP) and Financial Services based upon the percentages of effort stated in the budget justification in the proposal. Financial Services uses these percentages to allocate the proper proportion of each employees' salary to the grant.
At the end of every semester (including the summer semester), OSP and Financial Services prepare an effort report for each employee who was paid by a grant, reflecting the actual percentage of his/her salary that was charged against the grant. This percentage will match the payroll distribution data submitted prior to the beginning of the grant, unless subsequent changes were made. OSP will send the effort reports to the PIs, who will distribute them to everyone who worked on their projects. Each individual will sign his/her own report, certifying that he/she actually performed the level of effort on the project that is indicated in the effort report, and for which they were paid. Any necessary changes to the percentages will be indicated on the report.
The PIs will collect the effort reports and return them to OSP. These forms must be submitted three times per year (see chart below).
If an employee’s effort is not certified on even one federal project, the University is obligated by law to remove the individual from all projects and to stop any further payments.
Time Period WorkedJune and July
August 1 - Dec 30
January 1 - May 31
Effort Report DueDecember 31
Why does Armstrong require effort reports?
First, effort reporting is a fiscally sound method of monitoring expenses and documenting cost sharing and is a part of the University accounting system. Second, effort reporting is a federal requirement. As a condition of receiving federal funding, Armstrong must maintain an accurate system for reporting the effort that employees devote to federally sponsored projects. To ensure that actual time records agree with the amount of effort that that has been expended on grants, Armstrong's internal auditor conducts a periodic check (at least once annually) of a small sample of effort reports and payroll records, to confirm that the effort reports have been prepared and signed appropriately and match up with the amount of effort that has been charged to the grants. While timely and accurate reporting is simple to do, the penalties for not doing so are severe. A case in point:
East Carolina University – was obligated to reimburse NIH $565,820 in already spent grant funds. University had not implemented an effort reporting system adequate to comply with the federal requirements and document the actual efforts of covered employees. Instead, the University relied upon an incomplete, inconsistent system that was subject to frequent errors and could be easily manipulated. Some employees reported percentage of time and effort while other employees reported the numbers of hours supposedly worked while other employees didn’t report at all. http://oig.hhs.gov/oas/reports/region4/40401001.pdf
When is it necessary to correct effort shown on a report?
When there is a 5% or more variance within one’s total effort. For instance if you were awarded another grant, but your course load etc remained the same, you would have to change the effort on the first grant in order to accommodate the effort you will be spending on the second. Changes of more than 5% must be noted on your effort report and authorized by the PI. The program officer must be notified if an individual’s effort is reduced by more than 25%. Remember, effort cannot exceed 100%.
Who is responsible for effort reporting?
Everyone shares overall responsibility for maintaining a functional reporting system because everyone stands to lose if we are lax. With that said, the PIs are responsible for overseeing and tracking the process on their projects. OSP will work with the PIs to make sure forms are distributed and collected in a timely manner.
OSP will offer mandatory training sessions for new PIs and researchers as soon as word is received that their grant has been awarded. Refresher courses are also available upon request.