Time and Effort Reporting Policy

Federal Regulations of OMB Circular A-21

Under the provisions of the Office of Management and Budget Circular A-21, the federal government requires an effort report when an individual is compensated by, or has agreed to contribute time to, a federally-sponsored project. All employees funded with federal dollars must complete time and effort reports. All faculty who serve as investigators on sponsored agreements are personally responsible to certify the amount of effort that they and their employees spend on sponsored activities.

Time and effort reporting is required when any part of an individual's salary is charged to a federal program or used as match for a federal program. This requirement is subject to audit, unallowable costs are subject to repayment, and irregularities with reports can be cause for institutional or individual disallowances.

All individuals who devote effort to sponsored activities, whether or not they are paid, are subject to effort reporting. Faculty, regardless of their role on the grant must certify their own effort reports. The Principal Investigator must certify the work of non-faculty project staff charged to the grant. These reports not only document the distribution of effort but also the appropriateness of salary and wage charges to federal grants and contracts.
(OMB Circular No A21 J10c(2))

Definition of Effort

Effort is defined as the amount of time an employee devotes to fulfilling his/her College responsibilities. Effort reporting certifies that

  • Effort supported (paid) by a federally-sponsored project has been performed as promised.
  • Effort expended in support of a federally-sponsored project, but not paid by the project, has been performed as promised

(OMB Circular No A21 J10c(2)(a)-(f))

Effort is the portion of time spent on a particular activity, expressed as a percentage of the individual's total activity for the university. It is NOT based on 40 hour work week, but on 100% of faculty activities including instruction, administration (chair, dean responsibilities) committee service, research without external funding, and sponsored project activities.

If a PI works 60 hours per week, 30 hours represents 50% effort

Estimate of weekly hours spent on the sponsored project divided by total hours in an average work week equals effort on the sponsored project

The effort percentages must total 100%.

Time and Effort Reporting

Time and effort reporting makes salary sources for the period congruent with effort spent for the period. Distribution of effort should represent a reasonable estimation of the actual effort expended during the term being certified. There is no standard form.
(OMB Circular No A21 J10b(1))

Semi-Annual Certification Report

Hartwick College uses after-the-fact time and effort certification. The Office of Corporate, Foundation, and Government Relations will distribute report forms at the end of each semester and the summer. Report periods are defined as, Fall Semester: September through December inclusive, Spring Semester: January through May inclusive, and Summer: June through August inclusive.

The semi-annual certification report must be submitted to the Controller no later than 15 days following the end of each semester and summer. These must be signed by the employee or supervisor with first hand knowledge of the work. There must be documentation to verify the underlying basis of the report, actual effort, not estimated effort. PIs are advised to consult supporting documentation when completing reports ie. calendar, work product, time log, etc. Audits have specifically reviewed the documentation used in completing reports.

Compliance Issues

Auditors will comment on any of the following:

  • Late reports
  • Effort certified by someone without first-hand knowledge
  • Percentage outside of sponsored project not credibly sufficient to cover teaching, clinical, administrative or other university work.
  • Revisions to Time and Effort Reports
  • Significant data inconsistency between effort report and other documentation such as:
    • Clinical time reports
    • Outside activity forms
    • Other support forms
    • Leave reports

(OMB Circular No A133 Section_.525(d)(1) regarding audits )

Summary

Compliance with time and effort reporting has become more stringent and is subject to audit. Federal auditors include effort reporting as a specific audit focus. Each individual is responsible for certifying his/her own effort, which is NOT based on a 40 hour work week. It is based on the individual's own work week. Effort reporting tracks the reasonable estimation of actual activity on projects and should not simply mimic budgeting amounts.

Resources

• OMB Circulars http://www.whitehouse.gov/omb/circulars/

• NSF Proposal Guide http://www.nsf.gov/pubs/gpg/nsf04_23/