Effort Reporting –Rising Above the
Challenge

OMB Circular A-21 Cost Principles for Educational Institutions

OMB Circular A-110 Uniform Administrative Requirements for Grants &
Agreements with Institutions of Higher Education, Hospitals and Other
Non-Profit Organizations

Tennessee Code Annotate

Sponsor Terms and Conditions

TBR Policies and Guidance

Institutional Policies and Procedures/Practices

Sponsored Programs Policies and Procedures

A Guide to Managing Federal Grants
The proportion of time spent on any activity and
expressed as a percentage of the total
professional activity for which an individual is
compensated.
Restated:
Effort is how someone spent or expended their
time.
When writing a proposal, the amount of time
expressed in dollar amounts or percentages
(effort) has to be tracked and verified
throughout the life of the award whether
salary is charged directly, indirect or not at all
to the grant.
$50,000 salary- request $10,000 =20% effort
commitment.
$69,000 salary- commits 20% = $13,800
allowable charge to the grant
Council of Government Regulation (COGR)
definition of effort reporting
“Effort reporting is the mechanism used to
confirm that salaries and wages charged to
each sponsored agreement are reasonable in
relation to the actual work performed.
Certification of an effort report must
reasonably reflect the activities for which the
employee is compensated by the institution.”
Anyone charged to a federal award must certify
that the salary paid or the commitment proposed
is reasonable in relation to the effort (activity)
devoted to the award.
This includes individuals shown as match to
federal awards and those with unpaid
commitments.

NOT based on 37.5 hour work week
Based on the total amount of time needed
to perform the activities for which one is
compensated by the institution including:
- Sponsored project activities
- Non-sponsored project activities

o Administration (including duties as chair, dean,
etc)
IBS is annual compensation paid by the college
for an employee’s appointment.
The institution must establish what is included
in the base salary of each employee.
JSCC IBS for faculty includes:
instruction, office hours,
advising, committee service, curriculum development, faculty
development, public service and research

If you work 60 hours a week, 30 hours
represents 50% effort

If a lab assistant works 20 hours a week, the
20 hours represents 100% effort

In a typical week Professor Y estimates that
she works 54.5 hours.
Sponsored Project A
(Federal)
10
Sponsored Project B
(Foundation)
7
Instruction/office
Committee and
Other admin
Total
30
7.5
54.5
Circular A-21 requires that institutions
receiving federal awards maintain procedures
documenting the distribution of activity, and
associated payroll charges, to each sponsored
agreement.

Signed effort reports are considered legal documents in
which an individual attests to the accuracy of the effort spent
on sponsored projects

Erroneously certifying effort reports can be viewed as fraud

We are obliged by federal regulations to exercise good
stewardship of those funds
1.) Effort is a part of that stewardship
2.) Personnel costs are the majority of research costs
False Claims Act, 31 U.S.C., sections 3729 & 3721
Difference between effort reporting and payroll
distribution….
•
Effort reporting is how you spent your time
•
Payroll distribution is how you are paid
•
Effort drives the payroll distribution
•
Payroll distribution does not drive the effort
certification
Estimate of weekly hours spent on sponsored project
Total hours in an average work week
% of effort
=
on
Sponsored
Project
When Professor Y certifies her effort, it should
be reasonably estimated as follows:
Sponsored Project A
(federal)
10
18%
Sponsored Project B
(foundation)
7
13%
30
55%
7.5
14%
54.5
100%
Instruction/office
Committee and other
admin
Total
Percentage
18%
Sponsored Proj A
13%
69%
Sponsored Proj B
Instituition
Commitment
Note: It is on rare occasions that University’s and
College’s charge extra compensation, above IBS, to
federal awards. Such cases should occur only when:
◦ Work crosses departmental lines or
◦ Involves a separate or remote operation and
◦ Work is in addition to regular department load and
◦ Specifically provided for in the agreement and approved in
writing by sponsoring agency
Circular A-21 section J(10) d


Professor Y submits another proposal
The new project will be require 5 hours,
every weekend, for 15 week.
Sponsored Project A
(federal)
215
26%
Sponsored Project B
(foundation)
109
13%
75
9%
Instruction/office/other
432
52%
Total
831
100%
Sponsored Project C
(federal) Extra Comp
All 3 criteria must apply for a cost to be
charged directly to a federal project:
•
The cost must be allowable under both the
provisions of A-21 AND under the terms of a
specific project
•
The cost must be allocable, meaning it can be
associated to a project with a high degree of
accuracy
The cost must be reasonable, meaning it reflects
what a “prudent person” would pay in like
circumstances
•

Salaries and wages charged inappropriately to sponsored
projects

Employees not being properly trained

Reports not certified in timely manner

Missing or incomplete documentation that serves as “suitable
means for verification” of effort

Weakness in the reporting system

Effort certified by individuals with insufficient knowledge of the
work performed

Northwestern University- $5.5 million

South Florida - $4.1 million

University of California - $2.1 million

John Hopkins University – $2.6 million

University of Connecticut - $2.5 million

www.whitehouse.gov/omb/circulars_default

www.tennesseeanytime.org/laws/laws.html

www.gpoaccess.gov/cfr/

www.tbr.edu
Celebrating Success As A Team