Effort Reporting and Certification at Carroll University

Responsible Office or Person: Business Office
Related Law & Policy: CFR 200.430

Scope

Any Carroll employee working on a federally-sponsored project who has any portion of his or her salary charged to the project or to a cost share on the project must go through the process of effort reporting and certification. This is in accordance with federal guidelines as described in The Office of Management and Budget 2 CFR 200.430 “Compensation – Personal Services” which states that the federal government requires an effort report when an individual is compensated by, or has agreed to contribute time to, a federally-sponsored project. Time and effort reporting is required when any part of an individual's salary is charged to a federal program or used as cost share for a federal program.

Carroll University’s effort reporting system provides an “after-the-fact” confirmation that the salaries paid to individuals reasonably reflect the actual amount of effort expended on a project on a term basis.

Principal Investigators (PI) or Project Directors (PD) should expect that effort reports will be reviewed at the end of the effort reporting period.

Policy Statement

Responsibility for any project lies with the PI/PD. It is the PI/PD’s obligation to collect, review, and certify reports for key personnel on the project. He or she must see to it that his or her own report is certified by an appropriate supervisor and ensure that all reports are turned in within 30 days of the end of the term or the end of the project. The Business Office and the Grants Staff are available to assist the PI/PD with this process, but do not take responsibility for ensuring accuracy or timeliness of reports.

Effort reporting is subject to federal audit. The federal government can impose severe penalties and funding disallowances as a result of missing, inaccurate, incomplete, or untimely effort reporting. Carroll University expects that PI/PDs will meet this obligation. At the discretion of the administration, payment using grant funds for effort expended on the grant may be reclassified to the PI’s operating budget if time and effort reports are not complete.

Compliance

1. All personnel on sponsored projects must be approved by senior administration before an award can be accepted by the institution. Personnel cannot be added to any funded project without approval from both the University and the sponsoring agency.

2. Effort reporting shall reasonably reflect the percentage distribution of effort expended by Carroll University employees involved in federally funded sponsored projects including those in which the federal funds flow through another agency.

3. Each employee whose time is committed to a federally sponsored project shall complete a time and effort certification report. Committed cost sharing (specified in the budget and approved in the proposal stage) must be included in effort reports. The report must be completed within 30 days of the end of the term or the end of the project using the appropriate form.

4. The Business Office is responsible for the retention of all employee effort reports. Individually reported data will be made available to authorized auditors.

5. The Effort Certification report must represent, in percentages totaling 100%, a reasonable estimate of an employee’s effort for the term being reported. 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 a 40 hour work week, but on 100% of the employee’s activities including contractual obligations such as instruction, service, research, administration, and sponsored project activities. It is not possible for effort to exceed 100%. Note: It is recognized that research, instruction, and service are often inextricably intertwined and estimates will be necessary in most cases.

6. People who serve as Principal Investigators (PI) or Project Directors (PD) on sponsored projects rely on direct supervisors to review and certify the effort employees spend on sponsored projects under their direction. The effort of the PI/PD must be certified by a supervisor.

7. If changes are made to the amount of effort expended by any key personnel on a project, the PI/PD must notify the Grants Staff and obtain approval from the University and the sponsor before changes are enacted.

8. Certain sponsors limit the annual rate of salary reimbursement. Carroll University follows agency guidelines for each sponsor. PI/PDs must still devote the full committed effort as proposed and awarded without regards to salary reimbursement limitation.

9. Training will be provided on effort reporting and certification requirements by the Grants Staff.

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