Effort Reporting and Certification

Effort Reporting - Why do we have to do this?

Effort Reporting is how we provide assurance to a grant sponsor that:

  • Salaries charged to a sponsored project are reasonable in relation to the work performed, and

  • Faculty and staff have met their commitments to a sponsored project.

Below are the top 10 things a P.I. (Principal Investigator) should know about effort:

  1. Effort is your work on a project, whether the sponsor pays your salary or not.

  2. When you write yourself into a grant proposal, you are committing your effort to the sponsor.

  3. If you reduce your effort, paid or unpaid, on a federal grant by 25%, you must have agency approval. If you reduce your paid effort, you may choose to document cost-sharing so that the total effort does not decrease.

  4. Many activities cannot be charged to a federally sponsored project. For example, the time you spend on these activities cannot be charged: Writing a proposal, serving on an IRB, IACUC or other research committee, serving on a departmental or university service committee.

  5. If you work on a sponsored project, you must certify your effort.

  6. Certifying effort is not the same as certifying payroll.

  7. Certification must reasonably reflect all the effort for all the activities that are covered by your University compensation.

  8. Effort is not based on a 40-hour work week. It's not based on hours at all.

  9. Effort must be certified by someone with suitable means of verifying that the work was performed.

  10. In identifying audit findings, auditors look for indications that certification was based on factors other than actual, justifiable effort.

The following was taken from the NCURA 14th Annual Financial Research Administration Conference, New Orleans, March 10-12, 2013.

Jeremy Forsberg, University of Texas at Arlington, and David Ngo, University of Wisconsin, Madison.

Faculty time - adding it up

  • Faculty activities are often intermingled (research, teaching, service).

  • Research activities are much broader than the time spent on projects that are funded.

  • Much of your time on sponsored projects may be voluntary uncommitted cost sharing (compare this to committed effort - just didn't receive "pay" for the time contributed).

  • The number of hours worked towards faculty activities still comprise 100% effort.

  • Effort is based on percentages of time towards a sponsored project relative to a faculty member's total activities.

Understanding the Intent of Effort Reporting

In a grant proposal, you offer effort. At award time, you make a commitment of effort. Throughout the project, you charge salary to the sponsor. Periodically, sponsors want to know: 1) have you devoted enough effort to justify the salary charges? and 2) even in cases where you are not charging salary to the sponsor, have you fulfilled your commitments?

What is Effort Certification?

Effort certification (or effort reporting) is the means of assuring sponsors that:

  • salary charges are justified (or "they got what they paid for")

  • PI's devoted the effort that was promised in the proposal

Certification is required for individuals who have paid or committed effort on sponsored projects. Effort must be certified by a person who can verify that the work was performed.

  • Faculty, academic staff, and all PI's certify their own effort

  • PI's certify for graduate students and non-PI classified staff who work on their projects

Effort reporting is not an exact science.

  • Precision is not required

  • Sponsors recognize that research, teaching, service, and administration are often inextricably intermingled

  • Reasonable estimates are expected, but there are some rules to follow!

The Rules Require us to:

  1. Be careful about what we offer in a proposal

  2. Be careful when making commitments at award time

  3. Change commitments when needed, and document the changes

  4. Fulfill commitments

  5. Charge salary in a way that's congruent with actual effort

  6. Certify effort in a way that's congruent with what actually happened

  7. Do not charge a grant for time that doesn't pertain to the grant

  8. Do not charge a grant for time spent writing a proposal for a new project or a competing continuation

  9. Transfer salary charges off of a grant if the level of effort does not justify the salary charges

Why We Want to Get this Right

The consequences of NOT providing sufficient effort reporting and certification can be dire for the university. Effort reporting is the #1 target for federal auditors, and many universities have paid millions of dollars in fines.

How Do I Report and Certify Effort on My Grant?

Simple Time and Effort Report Form - may only be used when your compensated time and effort is 100% on one activity for the time period specified.

Activity Distribution Report - should be used when your time and effort is split between two or more activities for the time period specified.

Depending on your specific grant, we recommend that you report and certify your time and effort on a semester basis. Effort reporting should be provided for anyone receiving compensation from the grant, or anyone with a time commitment on the grant project, compensated or not. If you have any questions about this, please contact the Research and Grants Center.