Time & Effort Reporting Policy
As a recipient of federal funding, Southwestern Oklahoma State University (SWOSU) is required to comply with the Office of Management and Budget Circular Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards “(Uniform Guidance)" as well as other federal requirements for certifying effort expended on sponsored awards. SWOSU requires all individuals who receive federal sponsored funding to comply with University policies and sponsoring agency regulations regarding the proposing, charging and reporting of effort on those awards.
University faculty and staff are expected to charge their time to sponsored awards commensurate with the committed effort expended on all activities they perform. Payroll charges to sponsored awards, and cost sharing recorded for faculty and staff, serve as the initial data points for the University’s effort reporting system.
Reason for Policy
The Uniform Guidance Subpart E §200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The University’s practice is to utilize an after-the-fact effort reporting system to certify that salaries charges, or cost shared to sponsored awards, are reasonable and consistent with the work performed. The individual’s effort is first assigned to the specific awards in the payroll system based on anticipated activities. Actual effort expended on each project is certified by a responsible person with suitable means of verification that the work was performed, generally the principal investigator, at the end of specified reporting periods. The effort certification should be a reasonable estimate of how time was expended. Section §200.430© 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.”
The monthly Time and Effort certifications are the primary means for complying with the federal regulations relating to effort certification.
Who Must Comply
All individuals involved with the administration and conduct of federally sponsored award activities, including central and departmental sponsored project administrators, principal investigators, and other research personnel must comply with this policy.
Adherence to this policy is required for all effort related to federally sponsored awards as well as any non-federal awards where the non-federal sponsor requires effort reporting.
1. Time & Effort Certification
- Effort certifications must be completed monthly.
- Changes to the certified effort report must be requested in writing by the employee whose effort is being changed, or in the case that the employee has terminated, by someone having specific knowledge of that employee’s effort distribution. The request must justify the change and include an explanation of why the original certification was incorrect.
- Any approved retroactive payroll adjustments will require that a revised effort certification be completed.
- The certified effort distributions are used to support financial and programmatic information submitted to federal, state, accreditation agencies and other internal entities.
- An annual certification must be completed by the Principal Investigator at the end of each fiscal year.
Effort is the time spent on any activity by an individual and is expressed as a percentage of the individual’s University Effort. NOTE: 100 percent effort does not equate to any set number of hours, e.g. 40 or 50 hours per week; it equates to the totality of the University-compensated effort.
University Effort is the total effort for which an individual is compensated by the University. 100% effort includes teaching, research, public service, administrative and other University related activities. This ordinarily does not include outside consulting, professional work on an advisory board, participating on a peer review panel, or volunteer work. University effort is normally calculated on an employee’s base salary.
Effort certification is affirmation by the individual with direct knowledge or a suitable means of verification that the work was performed, stating that salaries and wages distributed to sponsored programs as direct charges are reasonable in relation to total University work performed over the monthly certification period.
Effort reporting is a federal compliance requirement. There are many individuals involved in this process and each one has a role in ensuring that certifications are accurate and completed on time.
Principal Investigators (PIs)
- Understand their own as well as their staff members’ (non-faculty personnel) levels of effort committed, charged and reported on all applicable awards.
- Review, initiate corrections if necessary, and certify their individual time and effort form.
- Communicate significant effort changes to the Grants and Contracts Accountant and payroll officer.
- Review salary charges on awards on a routine basis with Grants and Contracts Accountant and identify any effort-related changes and communicate with administrators to post corrections if needed.
- Recertify and sign if effort changes are made after a statement has been certified.
- Complete the annual Principal Investigator’s certification.
- Communicate significant changes in effort to funding agency.
- Help ensure compliance with the University Effort Reporting Policy.
- Take corrective action when notified of outstanding Effort Reporting forms greater than 10 days past due.
- Approve and sign all University Effort Reporting forms prior to submission to Grants and Contracts Accountant.
Grants and Contracts Accountant
- Monitor effort commitments, salary charges, and cost sharing on all applicable awards.
- Communicate to the sponsored programs office (OSP) any changes that require sponsor notification and/or approval.
- Review salary charges with PI/faculty member and ensure any salary distribution updates and/or corrections are done by the payroll officer in a timely manner.
- Check effort certifications for accuracy during the review period.
- Ensure that effort certifications are completed within certification period.
- Monitor to ensure compliance with, University Effort Reporting Policy.
- Coordinate with the University central sponsored programs offices (OSP) on any questions or issues.
- Update effort commitments in the system to reflect new effort commitment when changes in effort are approved by sponsors.
- Manage the business/functional aspects of the electronic effort reporting system.
Office of Sponsored Programs
- Maintain the University Effort Reporting Policy.
- Provide effort reporting training, guidance on requirements, and oversee University-wide compliance with University Effort Reporting Policy.
The University and OMB require an Effort Certification for those individuals whose salary is being charged directly to federal sponsored programs. Training is required of all individuals who are responsible for certifying effort.